TMI Blog2011 (10) TMI 744X X X X Extracts X X X X X X X X Extracts X X X X ..... rder dated 23-11-2007 passed by the Income Tax Appellate Tribunal, Bangalore Bench 'B' (hereinafter referred to as 'ITAT') in ITA No. 1000/Bang/2007 wherein the ITAT has held that payment made towards purchase of 'shrink wrap' cassettes/CDs by the respondent from non-resident company based in Singapore would not amount to royalty and has set aside the order passed by the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the non-resident supplier of software has been held to be a royalty by answering the 'substantial question of law in favour of the revenue and against the assessee in ITA No-2808/2005 and connected cases, decided on 15-10-2011. Following the detailed reasons assigned therein, we hold that the order passed by the ITAT impugned in this appeal is liable to be set aside and we answer the substa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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