2012 (6) TMI 232

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....DGMENT 1. The revenue has preferred this appeal against the order passed by the Tribunal which has granted relief to the assessee. 2. In fact, the substantial question of law which arises for consideration in this appeal arose for consideration before this court in two appeals, firstly, in the case of CIT v. Synopsis International Old Ltd. in IT Appeal No s.11 to 15/2008 decided on 3.8.2010 ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....'royalty' and that the same did not give rise to any 'income' taxable in India and, therefore, the appellant[s] was not liable to deduct any tax at source?" 4. In both the cases, it was held that consideration paid by the Indian customers or end-users to the assessee-a foreign supplier, for transfer of the right to use the software/computer programme in respect of the copyrights falls within th....