https://www.taxtmi.com/caselaws?id=243190 The case involved an appeal by the Revenue against an order under Section 195 of the Income Tax Act. The Income Tax Appellate Tribunal reversed the initial order, prompting the framing of a substantial question of law regarding the tax liability for payments to a non-resident entity. The Tribunal's decision was influenced by a Delhi High Court ruling on the definition of royalty under Section 9(1)(vi) of the Act, leading to a directive for reassessment under the Double Taxation Avoidance Agreement between India and the USA. The High Court emphasized the need to consider statutory amendments and international agreements in determining tax implications. en-us Tue, 12 Nov 2013 00:00:00 +0530 Mon, 27 Jan 2014 21:43:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243190 The case involved an appeal by the Revenue against an order under Section 195 of the Income Tax Act. The Income Tax Appellate Tribunal reversed the initial order, prompting the framing of a substantial question of law regarding the tax liability for payments to a non-resident entity. The Tribunal's decision was influenced by a Delhi High Court ruling on the definition of royalty under Section 9(1)(vi) of the Act, leading to a directive for reassessment under the Double Taxation Avoidance Agreement between India and the USA. The High Court emphasized the need to consider statutory amendments and international agreements in determining tax implications. Case-Laws Income Tax Tue, 12 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243190