https://www.taxtmi.com/caselaws?id=236684 Receipts from sale or licensing of software were treated as royalty in substance, but the additions could not survive in the assessee's hands because the same income had already been brought to tax in the hands of another entity in the distribution chain. Following its earlier decision on materially identical facts, the ITAT deleted the additions. The separate limitation ground for one assessment year was not pressed and was rejected without adjudication on merits. en-us Wed, 29 Feb 2012 00:00:00 +0530 Thu, 05 Sep 2013 09:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236684 Receipts from sale or licensing of software were treated as royalty in substance, but the additions could not survive in the assessee's hands because the same income had already been brought to tax in the hands of another entity in the distribution chain. Following its earlier decision on materially identical facts, the ITAT deleted the additions. The separate limitation ground for one assessment year was not pressed and was rejected without adjudication on merits. Case-Laws Income Tax Wed, 29 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236684