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Showing contexts for: computer includes computer software in Dcit-Circle 1(3)(1), Mumbai vs Diebold India Private Limited, Mumbai on 9 March, 2026Matching Fragments
4. Whether on the facts and circumstances of the case and in law, Ld. CIT(A) was justified in deleting the disallowance of Rs. 18,42,93,456/u/s 40(a)(i) of the Income Tax Act, 1961(the Act)' by holding that assessee company is not required to deduct tax u/s 195 of the Act for payment for purchase of software products from Diebold Inc. ignoring the Explanation 4 to Section 9(1)(vi) of the Act inserted by Finance Act, 2012 with retrospective effect from 01.06.1976 which clarifies that the transfer of all or any rights in respect of any right, property or information has always included transfer of all or any right for use or rig ht to use a computer software (including granting of a license)?