https://www.taxtmi.com/caselaws?id=460790 Payments made to foreign companies for purchase of licensed software were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act, because the issue was governed by the Supreme Court's decision in Engineering Analysis Centre of Excellence (P.) Ltd. The Revenue could not displace that binding precedent, and the request for liberty to seek review depending on pending proceedings before the Supreme Court did not alter the substantive legal position. The substantial question of law was answered in favour of the assessee, and the impugned order was set aside to that extent. en-us Mon, 02 Sep 2024 00:00:00 +0530 Wed, 09 Jul 2025 17:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460790 Payments made to foreign companies for purchase of licensed software were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act, because the issue was governed by the Supreme Court's decision in Engineering Analysis Centre of Excellence (P.) Ltd. The Revenue could not displace that binding precedent, and the request for liberty to seek review depending on pending proceedings before the Supreme Court did not alter the substantive legal position. The substantial question of law was answered in favour of the assessee, and the impugned order was set aside to that extent. Case-Laws Income Tax Mon, 02 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460790