2024 (1) TMI 367

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....RAJIV SHAKDHER AND HON'BLE MR. JUSTICE GIRISH KATHPALIA For the Appellant Through: Mr Ruchir Bhatia, Senior Standing Counsel. For the Respondent Through: Mr Satyen Sethi and Mr Arta Trana Panda, Advocates. RAJIV SHAKDHER, J. (ORAL): 1. This appeal concerns Assessment Year (AY) 2009-10. 2. Via the instant appeal, the appellant/revenue seeks to assail the order dated 31.03.2022 pa....

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....e said amount received by the respondent/assessee as royalty. 5. The finding of fact returned by the statutory authority is that the respondent/assessee had not transferred the copyright it had qua the subject software. The Tribunal, with regard to the said issue, in our opinion, ruled correctly, in favour of respondent/assessee and concluded that the amount could not be treated as royalty with....