https://www.taxtmi.com/caselaws?id=466657 Question whether royalty is taxable on a receipt basis is precluded from re consideration because the same issue was previously decided for the assessee in favour of the assessee; consequently that issue is not entertained. The appeal is admitted solely on the discrete legal question whether payments for software constitute 'royalty' under the applicable domestic law and the India Germany DTAA, with the matter directed to be heard together with a related appeal; the appeal remains pending for determination of that characterisation issue. en-us Thu, 10 Jan 2013 00:00:00 +0530 Mon, 16 Feb 2026 14:24:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466657 Question whether royalty is taxable on a receipt basis is precluded from re consideration because the same issue was previously decided for the assessee in favour of the assessee; consequently that issue is not entertained. The appeal is admitted solely on the discrete legal question whether payments for software constitute 'royalty' under the applicable domestic law and the India Germany DTAA, with the matter directed to be heard together with a related appeal; the appeal remains pending for determination of that characterisation issue. Case-Laws Income Tax Thu, 10 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466657