https://www.taxtmi.com/caselaws?id=794657 A fresh legal claim on the taxability of receipts as royalty can be raised in appeal against an intimation under section 143(1) even where the return was processed without adjustment, because there is no estoppel against law and tax can be levied only by authority of law; the claim was held maintainable. Receipts from software sales were stated not to be royalty if the software was sold only as copyrighted articles without transfer of copyright, but that factual question had not been examined and was remitted to the AO for limited verification with an opportunity of hearing. en-us Fri, 05 Jun 2026 00:00:00 +0530 Thu, 09 Jul 2026 08:35:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794657 A fresh legal claim on the taxability of receipts as royalty can be raised in appeal against an intimation under section 143(1) even where the return was processed without adjustment, because there is no estoppel against law and tax can be levied only by authority of law; the claim was held maintainable. Receipts from software sales were stated not to be royalty if the software was sold only as copyrighted articles without transfer of copyright, but that factual question had not been examined and was remitted to the AO for limited verification with an opportunity of hearing. Case-Laws Income Tax Fri, 05 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794657