TMI Blog2023 (7) TMI 287X X X X Extracts X X X X X X X X Extracts X X X X ..... ndia Singapore Agreement - amounts paid by the concerned persons resident in India to non-resident - foreign software suppliers - Whether transaction constitutes as taxable income deemed to accrue in India u/s 9(1)(vi)? - HELD THAT:- The issue raised by the Revenue in the present special leave petition is covered against them vide judgment of this Court dated 02.03.2021 in Engineering Analysis C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hearing the counsel the Court made the following Delay condoned. The issue raised by the Revenue in the present special leave petition is covered against them vide judgment of this Court dated 02.03.2021 in Engineering Analysis Centre of Excellence Private Limited vs. The Commissioner of Income Tax Anr. reported in (2022) 3 SCC 321. Learned counsel appearing for the Revenue states th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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