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Reference in Article 13(3)(c) of Indo-Canada DTAA is to "any copyright" and it is not a reference to "any right" for purpose of terming a payment as `royalty’
Case Law Details
- Case Name
- Director of Income Tax Vs Sahara India Financial Corporation Ltd. (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
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CASE LAWS DETAILS
DECIDED BY: HIGH COURT OF NEW DELHI,
IN THE CASE OF: Director of Income Tax Vs Sahara India Financial Corporation Ltd., Appeal No: ITA No. 1064/2007, DECIDED ON: February 19, 2010
RELEVANT PARAGRAPH
BADAR DURREZ AHMED, J (ORAL)
1. This appeal preferred by the revenue is directed against the Income Tax Appellate Tribunal .s order dated 28.07.2006 passed in ITA No. 491/Del/2000 and relates to the assessment year 1998- 1999.
2. The revenue is aggrieved by the finding of the Tribunal that the payment of US $ 9,24,500/- by the assessee, as per the agreement dated 10.07.1996, to I...
