Income from supply of CAS & middleware products not falls under ‘royalty’

CIT (International Taxation) Vs Nagravision S.A (Delhi High Court) Delhi high court followed Engineering Analysis Centre of Excellence Ltd. Vs. CIT432 ITR 471 SC and held that the income from supply of CAS and middleware products to indian customers, does not fall under the ‘royalty’ as defined under Section 9(l)(vi) of the Income Tax Act, 1961 (‘the Act’) and Article 12(3) of the India- Swiss DTAA. FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT 1. Present income tax appeal has been filed challenging the order dated 31st January, 2022 passed by the Income Tax Appellate Tri...