TMI Blog2021 (9) TMI 1528X X X X Extracts X X X X X X X X Extracts X X X X ..... iers - HELD THAT:- Assessee submits that the substantial questions of law raised herein are squarely covered by the ruling of the Hon ble Apex Court in the case of Engineering Analysis Centre of Excellence Private Limited [ 2021 (3) TMI 138 - SUPREME COURT] held that amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/suppliers, as consideration ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sel for the appellant - assessee submits that the substantial questions of law raised herein are squarely covered by the ruling of the Hon ble Apex Court in the case of Engineering Analysis Centre of Excellence Private Limited vs. The Commissioner of Income Tax and another reported in (2021) 432 ITR 471 (SC). 2. Learned counsel for the respondents revenue could not dispute the same. 3. In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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