TMI Blog2016 (4) TMI 1403X X X X Extracts X X X X X X X X Extracts X X X X ..... ome - Whether fees received can be treated as royalty as defined under section 9(l)(vi) of the Income-tax Act, 1961, and under Article 12 of the applicable DTAA? - HELD THAT:- As conceded the questions which arise for consideration are already answered by the decision of this Court in the case of Commissioner of Income Tax Vs. Synopsis International Old Ltd.[ 2013 (2) TMI 448 - KARNATAKA HIGH COU ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ht in dismissing the Appellant s appeals by placing reliance on the judgment of this Hon ble Court dated 15.10.2011 in the case of Samsung Electronics in ITA No.2808/2005 and on its earlier orders dated 31.10.2012, 05.12.2014 and 06.02.2015 passed by its coordinate Benches in the Appellant s own appeals for the assessment years 2006-07, 2007-08 and 2008-09, respectively?; and 2. Whether, on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... International Old Ltd., reported at [2012] 28 taxmann.com 162 (Kar.). However, she submitted that the matter is carried before the Apex Court. 5. In view of the above, when the issues are already covered by the above referred decision of this Court, we do not find that any substantial question of law would arise for consideration. Hence, the present appeals are dismissed. - - TaxTMI - ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
