S N Enterprises vs Income Tax Officer & Ors. on 27 September, 2022
Author: Manmeet
holding that
the income earned by the Appellant from distributing of computer
software in India was royalty for the purposes of Section ... four categories:
i) The first category deals with cases in which computer
software is purchased directly by an end-user, resident in
India, from
Ashish Poddar vs Income Tax Officer Ward 54(1) & Anr. on 27 July, 2022
Mark Gulati vs Ito Ward 52(1) Delhi & Anr. on 27 September, 2022
Author
Somnath Virmani vs Dcit Circle 13(1) Delhi And Anr. on 27 July, 2022
Author
appellant-Revenue submits that ITAT has
erred in holding that licensing of software products of Microsoft in the
Territory of India by the Respondent ... case of the respondent-assessee involved making of multiple
copies of the software clearly indicating transfer of copyright.
4. Having heard learned counsel
hands of respondent on account of recharacterization of
receipts from sale of software licenses to Indian customers/distributors as
royalty. The ITAT, while upholding ... Respondent challenging
the findings of ITAT with regard to upholding taxability of software
receipts as royalty. The Cross Objections Nos. 18356/2011, 18359/2011
received by Microsoft Regional
Sales Corporation from the sale of MS Retail Software
Products to its distributors was assessable in the hands of the
appellant ... chargeable?
In the opinion of this Court, the issue of taxability of software receipts
in the present cases is no longer res integra
received by Microsoft Regional
Sales Corporation from the sale of MS Retail Software
Products to its distributors was assessable in the hands of the
appellant ... chargeable?
In the opinion of this Court, the issue of taxability of software receipts
in the present cases is no longer res integra
hands of respondent on account of recharacterization of
receipts from sale of software licenses to Indian customers/distributors as
royalty. The ITAT, while upholding ... Respondent challenging
the findings of ITAT with regard to upholding taxability of software
receipts as royalty. The Cross Objections Nos. 18356/2011, 18359/2011