Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
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ITAT held that software subscription receipts were consideration for access to a copyrighted article, not royalty or fees for technical/included services, because customers received only a non-transferable right to use the software and no technology was transferred or made available. That treatment applied to AYs 2020-21 to 2022-23. By contrast, separate professional services receipts in AY 2022-23 were found to be specialised, customer-specific technical and professional consultations, so they were taxable as FTS/FIS under the Act and the DTAA. Proportionate equalization levy paid on those taxable services was directed to be refunded.
ITAT held that software subscription receipts were consideration for access to a copyrighted article, not royalty or fees for technical/included services, because customers received only a non-transferable right to use the software and no technology was transferred or made available. That treatment applied to AYs 2020-21 to 2022-23. By contrast, separate professional services receipts in AY 2022-23 were found to be specialised, customer-specific technical and professional consultations, so they were taxable as FTS/FIS under the Act and the DTAA. Proportionate equalization levy paid on those taxable services was directed to be refunded.
Note: It is a system-generated summary and is for quick reference only.