https://www.taxtmi.com/caselaws?id=777602 Taxation does not operate on res judicata across assessment years, so an Assessing Officer is not bound by the treatment adopted in an earlier year and may assess the matter on the facts and law of the relevant year. Maintenance support and education and training receipts linked to software sales were treated as inseparably connected with the software and, on that footing, could not be independently taxed as fees for technical services. The Revenue also failed to establish that the services made available technical knowledge, experience or skill under the treaty. The consistency argument failed, but the addition for the linked service receipts was deleted. en-us Fri, 22 Aug 2025 00:00:00 +0530 Tue, 02 Sep 2025 08:01:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777602 Taxation does not operate on res judicata across assessment years, so an Assessing Officer is not bound by the treatment adopted in an earlier year and may assess the matter on the facts and law of the relevant year. Maintenance support and education and training receipts linked to software sales were treated as inseparably connected with the software and, on that footing, could not be independently taxed as fees for technical services. The Revenue also failed to establish that the services made available technical knowledge, experience or skill under the treaty. The consistency argument failed, but the addition for the linked service receipts was deleted. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777602