https://www.taxtmi.com/caselaws?id=310500 Consideration for facilitating user rights in software to Indian entities was treated as royalty under the Act and the India-US treaty, following the assessee's own earlier years where the same issue had already been decided against it. No change in facts or circumstances was shown for the year under appeal, and the assessee had also filed an undertaking under section 158A(1) to await higher court decisions on the same question of law. The related grounds were dismissed, the appeal failed on the principal taxability issue, and the interest levy was treated as consequential. en-us Fri, 20 Feb 2015 00:00:00 +0530 Sat, 28 Oct 2023 08:35:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310500 Consideration for facilitating user rights in software to Indian entities was treated as royalty under the Act and the India-US treaty, following the assessee's own earlier years where the same issue had already been decided against it. No change in facts or circumstances was shown for the year under appeal, and the assessee had also filed an undertaking under section 158A(1) to await higher court decisions on the same question of law. The related grounds were dismissed, the appeal failed on the principal taxability issue, and the interest levy was treated as consequential. Case-Laws Income Tax Fri, 20 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310500