Interactive flat panels meeting automatic data processing conditions are distinguished from monitors, while later classification clarifications apply ...
Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of consideration for grant of software license is held not to be Royalty under the provisions of Income Tax Act, 1961, the question of consideration of the issue under the provisions as per DTAA between India and Netherland does not arise. Thus, ground of appeal No.1 filed by the assessee stands allowed. - AT
Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of consideration for grant of software license is held not to be Royalty under the provisions of Income Tax Act, 1961, the question of consideration of the issue under the provisions as per DTAA between India and Netherland does not arise. Thus, ground of appeal No.1 filed by the assessee stands allowed. - AT
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