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Fee for grant of software license, including software maintenance, consulting charges and training fees are not Royalty
Case Law Details
- Case Name
- TIBCO Software B.V. Vs ACIT (IT) (ITAT Pune)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
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TIBCO Software B.V. Vs ACIT (IT) (ITAT Pune)
Fee for grant of software license, including software maintenance, consulting charges and training fees, is not taxable in India
Facts- The appellant, is a non-resident company, engaged in sale of Software licences and provision of Software maintenance, Consulting and Training services in India. The ROI for AY 2011-12 was not filed by assessee. Thereafter, on receipt of information that the appellant had received income of Rs.33,96,623/- on which TDS had been deducted, the AO formed an opinion that income had escaped assessment to t...






