Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
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A fresh claim that software distribution receipts were not taxable as royalty was entertainable in appeal against an intimation under section 143(1), because there is no estoppel against law and tax can be collected only by authority of law. The later ruling in Engineering Analysis supported the assessee's right to contest the taxability despite having originally offered the receipts as income. On merits, software receipts would not be royalty if the distribution agreements conveyed only a limited right to resell copyrighted articles, without any transfer of copyright or rights to modify, copy or sub-license. As the agreements had not been examined on facts, the matter was remanded for limited verification of the nature of the software products and rights transferred.
A fresh claim that software distribution receipts were not taxable as royalty was entertainable in appeal against an intimation under section 143(1), because there is no estoppel against law and tax can be collected only by authority of law. The later ruling in Engineering Analysis supported the assessee's right to contest the taxability despite having originally offered the receipts as income. On merits, software receipts would not be royalty if the distribution agreements conveyed only a limited right to resell copyrighted articles, without any transfer of copyright or rights to modify, copy or sub-license. As the agreements had not been examined on facts, the matter was remanded for limited verification of the nature of the software products and rights transferred.
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