https://www.taxtmi.com/caselaws?id=311220 Receipts from supply of software were considered in light of Section 9(1)(vi) of the Income-tax Act and Article 12 of the India-USA DTAA. The controversy was treated as covered by the Supreme Court's ruling in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, which had already resolved the issue against the revenue. In view of that binding precedent, no separate adjudication was undertaken, and the position was accepted in favour of the assessee. en-us Thu, 01 Sep 2022 00:00:00 +0530 Thu, 14 Dec 2023 08:28:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311220 Receipts from supply of software were considered in light of Section 9(1)(vi) of the Income-tax Act and Article 12 of the India-USA DTAA. The controversy was treated as covered by the Supreme Court's ruling in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, which had already resolved the issue against the revenue. In view of that binding precedent, no separate adjudication was undertaken, and the position was accepted in favour of the assessee. Case-Laws Income Tax Thu, 01 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311220