2013 (1) TMI 986

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....CIT For the Respondent : Shri V. Balaji, CA ORDER PER ABRAHAM P. GEORGE, ACCOUNTANT MEMBER : In this appeal filed by the Revenue, it is aggrieved that the CIT(Appeals) deleted a disallowance made by the A.O. under Section 40(a)(ia) of Income-tax Act, 1961 (in short 'the Act') for non-deduction of tax at source, on payments effected by the assessee to one M/s Abaqus Inc. As per Revenue....

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....us Inc., were not royalty. Finding of the Tribunal was that what was acquired by the assessee was only a right of use a copyrighted software and not copyright in a software. In the assessment order itself, the A.O. has mentioned that the disallowance was being made despite Tribunal's ruling in favour of the assessee for keeping alive the issue. However, learned D.R. was unable to show any order of....