SC Rejects Petition seeking review of judgment in Engineering Analysis Centre

Commissioner of Income Tax Vs GE India Technology Centre Private Limited ETC. (Supreme Court of India) The Supreme Court’s decision marks a pivotal moment in the taxation of cross-border software purchases in India. With the rejection of the review petitions, the tax liability of foreign software sellers without a permanent establishment in India is reduced from the previous 10%-15% royalty tax to a 2% equalisation levy introduced via the Finance Act 2020. The court’s ruling builds upon its earlier judgment in Engineering Analysis Centre Of Excellence Private Limited vs. CIT (2021)...