https://www.taxtmi.com/caselaws?id=57779 The Tribunal ruled in favor of the assessee, holding that payments for imported software did not constitute 'royalty' under the relevant DTAAs and were not subject to tax deduction at source under Section 195 of the Income-tax Act. Consequently, the orders imposing tax and interest under Sections 201(1) and 201(1A) were set aside, and the appeals were allowed. The Tribunal did not address technical objections regarding jurisdiction or summons, focusing instead on the substantive issue of royalty classification under the DTAAs. en-us Fri, 18 Feb 2005 00:00:00 +0530 Tue, 14 May 2024 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57779 The Tribunal ruled in favor of the assessee, holding that payments for imported software did not constitute 'royalty' under the relevant DTAAs and were not subject to tax deduction at source under Section 195 of the Income-tax Act. Consequently, the orders imposing tax and interest under Sections 201(1) and 201(1A) were set aside, and the appeals were allowed. The Tribunal did not address technical objections regarding jurisdiction or summons, focusing instead on the substantive issue of royalty classification under the DTAAs. Case-Laws Income Tax Fri, 18 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57779