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Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The issue pertains to the taxability of income in India, specifically whether payments received by the respondent/assessee for supplying computer software are liable to be taxed as royalties u/s 9(1)(vi). The Court held that the issue stands covered by its previous order in Lucent Technologies, where it was observed that the supplier of software cannot be treated differently, and the same legal parameters would apply. Considering the Supreme Court's decision in Engineering Analysis Centre of Excellence and its own orders in Reliance Industries and Lucent Technologies, the High Court dismissed the appeal.
The issue pertains to the taxability of income in India, specifically whether payments received by the respondent/assessee for supplying computer software are liable to be taxed as royalties u/s 9(1)(vi). The Court held that the issue stands covered by its previous order in Lucent Technologies, where it was observed that the supplier of software cannot be treated differently, and the same legal parameters would apply. Considering the Supreme Court's decision in Engineering Analysis Centre of Excellence and its own orders in Reliance Industries and Lucent Technologies, the High Court dismissed the appeal.
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