https://www.taxtmi.com/caselaws?id=775527 A binding Supreme Court ruling on the taxability of subscription receipts had to be followed by revenue authorities, and it could not be ignored merely because a review petition had been filed or was pending. The impugned Section 197 certificate and related order were found unsustainable because they contained no independent reasoning and instead relied on an assessment treating the receipts as royalty under the India-US DTAA. As the Supreme Court decision in Engineering Analysis remained binding under Article 141, the order was set aside and the matter was remitted for fresh consideration in accordance with law. en-us Fri, 11 Jul 2025 00:00:00 +0530 Sat, 26 Jul 2025 08:39:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775527 A binding Supreme Court ruling on the taxability of subscription receipts had to be followed by revenue authorities, and it could not be ignored merely because a review petition had been filed or was pending. The impugned Section 197 certificate and related order were found unsustainable because they contained no independent reasoning and instead relied on an assessment treating the receipts as royalty under the India-US DTAA. As the Supreme Court decision in Engineering Analysis remained binding under Article 141, the order was set aside and the matter was remitted for fresh consideration in accordance with law. Case-Laws Income Tax Fri, 11 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775527