Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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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TaxTMI 
TaxTMI 
of 4915 
