2011 (10) TMI 744

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the revenue being aggrieved by the order dated 23-11-2007 passed by the Income Tax Appellate Tribunal, Bangalore Bench 'B' (hereinafter referred to as 'ITAT') in ITA No. 1000/Bang/2007 wherein the ITAT has held that payment made towards purchase of 'shrink wrap' cassettes/CDs by the respondent from non-resident company based in Singapore would not amount to royalty and has....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt i.e., payment made by the respondent to the non-resident  supplier of software has been held to be a royalty by answering the 'substantial question of law in favour of the revenue and against the assessee in ITA No-2808/2005 and connected cases, decided on 15-10-2011. Following the detailed reasons assigned therein, we hold that the order passed by the ITAT impugned in this appeal is l....