TMI Blog2024 (3) TMI 581X X X X Extracts X X X X X X X X Extracts X X X X ..... - HELD THAT:- Tribunal has ruled that neither income earned from licensing of software products nor subscription fee earned for providing cloud services, could be construed as royalty. Revenue, says that the proposed questions are covered by the judgment of the Supreme Court rendered in Engineering Analysis Centre of Excellence (P.) Ltd. [ 2021 (3) TMI 138 - SUPREME COURT] - We are also informed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of delay in filling the appeal. 3. According to the appellant/revenue, there is delay of 4 days. 4. Counsel for the respondent/assessee, says that he has no objection if the delay in filing the appeal is condoned. 5. Accordingly, the delay in filling the appeal is condoned. 6. The application is disposed of, in the aforesaid terms. ITA 96/2023 7. This appeal concerns Assessment Year (AY) 2014- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , it is not taxable under Article 7 of India-USA DTAA? C. Whether the Ld. ITAT erred in holding that the subscription received towards Cloud Services is not taxable as Royalty income under the provisions of Income Tax Act, 1961? 10. As would be evident the first two questions of law [i.e., A and B] relate to income earned from licensing/sale of software while the third question [i.e., C] relates t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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