https://www.taxtmi.com/highlights?id=80250 The case dealt with the taxability of income in India related to royalty receipts and Tax Deducted at Source (TDS) u/s 195. The respondent did not deduct tax on remittance to a foreign party for software procurement, claiming it wasn't royalty. Both the CIT(A) and Tribunal agreed. The High Court referred to precedent stating non-retrospective application of Explanation 6 to Section 9(1)(vi) of the Income Tax Act. The Supreme Court upheld this view, clarifying that Explanation 6 cannot be applied retrospectively. Rejecting the Revenue's attempt to apply Explanation 4 retrospectively, the court ruled in favor of the assessee. en-us Thu, 08 Aug 2024 09:10:24 +0530 Thu, 08 Aug 2024 09:10:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=80250 The case dealt with the taxability of income in India related to royalty receipts and Tax Deducted at Source (TDS) u/s 195. The respondent did not deduct tax on remittance to a foreign party for software procurement, claiming it wasn't royalty. Both the CIT(A) and Tribunal agreed. The High Court referred to precedent stating non-retrospective application of Explanation 6 to Section 9(1)(vi) of the Income Tax Act. The Supreme Court upheld this view, clarifying that Explanation 6 cannot be applied retrospectively. Rejecting the Revenue's attempt to apply Explanation 4 retrospectively, the court ruled in favor of the assessee. Highlights Income Tax Thu, 08 Aug 2024 09:10:24 +0530 https://www.taxtmi.com/highlights?id=80250