2023 (2) TMI 1177

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....ppal, Advocate. ORDER [Physical Hearing/Hybrid Hearing (as per request)] 1. This appeal concerns Assessment Year (AY) 2017-18. 2. This appeal assails the order of the Income Tax Appellate Tribunal [in short, "Tribunal"] dated 31.08.2022 passed in ITA 554/Del/2021. 3. The following questions of law are proposed by the appellant/revenue: "A. Whether on the facts and circumstances of the cas....

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.... Cloud Services is not taxable as Royalty income under the provisions of Income Tax Act, 1961?" 4. As would be evident the first two questions of law [i.e., A and B] relate to income earned from licensing/sale of software, while the third question [i.e., C] relates to subscription received against cloud services offered by the respondent/assessee. 5. The Tribunal has ruled that neither income e....