https://www.taxtmi.com/caselaws?id=470483 Departmental monetary limits bar Revenue appeals arising from regular assessments where the tax effect is below the applicable threshold; the international-taxation exception for tax-treaty disputes is confined to TDS/TCS litigation and does not extend to assessments under Section 143(3) read with Section 144C(3). The appeals were therefore not maintainable. Consideration for software and software upgrades was not taxable as royalty because no material displaced the appellate finding applying the governing Supreme Court decision. The deletion of royalty additions was sustained for all relevant assessment years. en-us Fri, 21 Mar 2025 00:00:00 +0530 Tue, 28 Jul 2026 19:00:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470483 Departmental monetary limits bar Revenue appeals arising from regular assessments where the tax effect is below the applicable threshold; the international-taxation exception for tax-treaty disputes is confined to TDS/TCS litigation and does not extend to assessments under Section 143(3) read with Section 144C(3). The appeals were therefore not maintainable. Consideration for software and software upgrades was not taxable as royalty because no material displaced the appellate finding applying the governing Supreme Court decision. The deletion of royalty additions was sustained for all relevant assessment years. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470483