https://www.taxtmi.com/caselaws?id=432411 Subscription receipts for services to be performed over a future period were to be recognised under the assessee's consistently followed revenue recognition policy, supported by AS-9 and the percentage completion method; because that method had been accepted in earlier years and no defect or change in facts was shown, the addition for unearned revenue was not sustainable. Payments for Red Hat subscriptions were not royalty or fees for technical services under the Act or the India-Singapore DTAA, because the arrangement covered open-source subscription support and did not transfer any copyright, licence, or right to exploit software, nor did it make available technical knowledge, skill, experience, process, or know-how. en-us Thu, 28 Jul 2022 00:00:00 +0530 Wed, 04 Jan 2023 11:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432411 Subscription receipts for services to be performed over a future period were to be recognised under the assessee's consistently followed revenue recognition policy, supported by AS-9 and the percentage completion method; because that method had been accepted in earlier years and no defect or change in facts was shown, the addition for unearned revenue was not sustainable. Payments for Red Hat subscriptions were not royalty or fees for technical services under the Act or the India-Singapore DTAA, because the arrangement covered open-source subscription support and did not transfer any copyright, licence, or right to exploit software, nor did it make available technical knowledge, skill, experience, process, or know-how. Case-Laws Income Tax Thu, 28 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432411