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Showing contexts for: access computer network in Ey Global Services Limited vs Assistant Commissioner Of Income Tax & ... on 9 December, 2021Matching Fragments
17. The submission mad+e by the learned counsel for the revenue relying upon the amendment to Section 9(1)(vi) of the Income Tax Act, 1961 has also been specifically considered and rejected by the Supreme Court.
Signature Not Verified Digitally Signed By:SHALOO BATRA WP(C) 11957/2016 & 12003/2016 Page 21 of 22 Signing Date:10.12.2021 18:30:1318. In view of the above, the Impugned Rulings dated 10.08.2016 passed by the learned AAR are set aside and it is held that the payment received by EYGSL (UK) for providing access to computer software to its member firms of EY Network located in India, that is, EYGBS (India), does not amount to „royalty‟ liable to be taxed in India under the provisions of the Income Tax Act, 1961 and the India-UK DTAA.