https://www.taxtmi.com/caselaws?id=307824 The Tribunal allowed the appeal, deleting the addition of Rs 29,49,80,527 as royalty taxable under the Income Tax Act, 1961, read with the India-Switzerland Double Taxation Avoidance Agreement. The Tribunal emphasized that the assessee's receipts did not fall under the definition of royalty as per relevant precedents. Additionally, the Tribunal justified the delay in pronouncing the order beyond 90 days due to the COVID-19 pandemic, citing extraordinary circumstances and the need for a pragmatic approach in interpreting time limits. en-us Mon, 13 Jul 2020 00:00:00 +0530 Wed, 10 May 2023 10:22:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307824 The Tribunal allowed the appeal, deleting the addition of Rs 29,49,80,527 as royalty taxable under the Income Tax Act, 1961, read with the India-Switzerland Double Taxation Avoidance Agreement. The Tribunal emphasized that the assessee's receipts did not fall under the definition of royalty as per relevant precedents. Additionally, the Tribunal justified the delay in pronouncing the order beyond 90 days due to the COVID-19 pandemic, citing extraordinary circumstances and the need for a pragmatic approach in interpreting time limits. Case-Laws Income Tax Mon, 13 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307824