https://www.taxtmi.com/caselaws?id=301092 Receipts from licensing of software-related manufacturing and distribution rights were disputed as royalty under the Income-tax Act and the India-US tax treaty. The Tribunal noted that an identical characterisation issue in the assessee's earlier years had already been sent back for fresh consideration in line with the jurisdictional High Court ruling in Infrasoft, and followed the same approach here. The matter was therefore remanded to the Assessing Officer for de novo adjudication in accordance with law and the earlier order, with the appeal treated as allowed for statistical purposes. en-us Wed, 31 Oct 2018 00:00:00 +0530 Sat, 12 Mar 2022 08:05:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301092 Receipts from licensing of software-related manufacturing and distribution rights were disputed as royalty under the Income-tax Act and the India-US tax treaty. The Tribunal noted that an identical characterisation issue in the assessee's earlier years had already been sent back for fresh consideration in line with the jurisdictional High Court ruling in Infrasoft, and followed the same approach here. The matter was therefore remanded to the Assessing Officer for de novo adjudication in accordance with law and the earlier order, with the appeal treated as allowed for statistical purposes. Case-Laws Income Tax Wed, 31 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301092