https://www.taxtmi.com/caselaws?id=301821 The Delhi HC noted that the Revenue's appeals involved the same treaty and statutory questions already decided in binding precedent: whether payments for software supply constitute royalty under Article 12(3) of the Indo-China DTAA, and whether interest under Section 234B is payable. As those issues had previously been decided against the Revenue, the court held that no fresh question of law arose for consideration. The appeals were therefore dismissed, and the earlier ruling was treated as controlling on both the treaty characterisation and the interest issue. en-us Fri, 18 Oct 2019 00:00:00 +0530 Thu, 21 Apr 2022 20:56:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301821 The Delhi HC noted that the Revenue's appeals involved the same treaty and statutory questions already decided in binding precedent: whether payments for software supply constitute royalty under Article 12(3) of the Indo-China DTAA, and whether interest under Section 234B is payable. As those issues had previously been decided against the Revenue, the court held that no fresh question of law arose for consideration. The appeals were therefore dismissed, and the earlier ruling was treated as controlling on both the treaty characterisation and the interest issue. Case-Laws Income Tax Fri, 18 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301821