2023 (2) TMI 1177

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.... For the Respondent : Mr. Akshay Uppal, 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: "....

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....Ld. ITAT erred in holding that the subscription received towards 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 resp....