2019 (10) TMI 1508

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....ate. For the Respondent : Mr. Harpreet Singh Ajmani and Mr. Rohan Khare, Advocates. ORDER C.M. No. 45711/2019 in ITA 911/2019 (exemption) C.M. No. 40377/2019 in ITA 817/2019 (exemption) 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. C.M. No. 45712/2019 (delay) in ITA 911/2019 3. By this application the applicant seeks condonatio....

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....lowing order came to be passed on that date: "ITA 763/2019, ITA 769/2019 & ITA 771/2019 3. At the outset, Mr. Ruchir Bhatia learned counsel for the Appellant very fairly states that the issues/questions framed in the present appeals are covered by the decision of this Court in Commissioner of Income Tax, International Taxation v. ZTE Corporation (2017) 392 ITR 80 (Delhi). The que....

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....for purchase and other transactions did not imply that it was royalty payment. In such cases, the nomenclature (of license or some other fee) is indeterminate of the true nature. Nor is the circumstance that updates of the software are routinely given to the assessee's customers. These facts do not detract from the nature of the transaction, which was supply of software, in the nature of articles ....