This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Royalty earned by NR from another NR not taxable in India even if payer embeds the now-how into products sold in India
Case Law Details
- Case Name
- Qualcomm Incorporated Vs ADIT, Circle 2(1) International Taxation (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2000-01 TO 2004-05
- Courts
- All ITAT, ITAT Delhi
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
ITAT DELHI BENCH ‘E’
Qualcomm Incorporated
Versus
ADIT, Circle 2(1) International Taxation
IT APPEAL NOS. 3696 TO 3699 AND 3700 (DELHI) OF 2009
[ASSESSMENT YEARS 2000-01 TO 2004-05]
JANUARY 31, 2013
ORDER
J. Sudhakar Reddy, Accountant Member
All these five appeals are filed by M/s.Qualcomm Incorporated and are directed against a common order passed by the CIT(A)-XXIX, New Delhi dt. 26-06-2009 for the A.Y. 2000-2001 to A.Y. 2004-2005. All these appeals arise from the assessments framed by the Assessing Officer (‘AO’) under section 143(3) read with section 147 of the I...





