satellite
by the payer as it has no control or possession of the satellite is not acceptable. To
constitute "royalty", it is not necessary ... which
the "process" is carried on should be in the control or possession of the payer.
The context and factual situation
laid on 'control'. The Supreme Court affirmed the conclusion of the
High Court that the effective control of machinery even while the
machinery ... right of control and direction
whereas the phrase 'right to use' implies the existence of such
control. Even in a case where
Deputy Commissioner Of Income Tax ... vs M/S Infosys Limited , Bangalore on 9 January, 2023
laid on 'control'. The Supreme Court affirmed the conclusion of the
High Court that the effective control of machinery even while the
machinery ... right of control and direction
whereas the phrase 'right to use' implies the existence of such
control. Even in a case where
retrieval,
communication and control;'
IT(TP)A Nos.139 & 2560/Bang/2019
Page 17 of 40
From the above definition, it follows that ... logic,
arithmetic, data storage and retrieval communication and control.
10.6.2 In the light of the above definition of 'Computer System', the
functions
laid on 'control'. The Supreme Court
affirmed the conclusion of the High Court that the effective control of
machinery even while the machinery ... found in the definition of "Royalty" under IndiaAustria DTAA. The
definition of "Royalty" under the DTAA is much more narrower
logic,
arithmetic, data storage and retrieval, communication
and control;' From the above definition, it follows that a
Page ... logic,
arithmetic, data storage and retrieval communication
and control.
10.6.2 In the light of the above definition of 'Computer
System', the functions
logic,
arithmetic, data storage and retrieval, communication
and control;' From the above definition, it follows that a
Page ... logic,
arithmetic, data storage and retrieval communication
and control.
10.6.2 In the light of the above definition of 'Computer
System', the functions
laid on 'control'. The Supreme Court
affirmed the conclusion of the High Court that the effective control of
machinery even while the machinery ... found
in the definition of "Royalty" under India-Singapore DTAA. The definition of
"Royalty" under the DTAA is much more narrower
laid on 'control'. The Supreme Court affirmed the conclusion of the
High Court that the effective control of machinery even while the
machinery ... right of control and direction
whereas the phrase 'right to use' implies the existence of such
control. Even in a case where
