Case Law Details
Case Name : DCIT Vs HP Services (Singapore) Pvt. Ltd. (ITAT Delhi)
Related Assessment Year : 2010-11
Courts :
All ITAT ITAT Delhi
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DCIT Vs HP Services (Singapore) Pvt. Ltd. (ITAT Delhi)
Ground No. 1 is challenge to the deletion of addition made by the AO qua consideration received by the Assessee from various entities on account of sale/supply of software, by treating as “royalty” within the meaning of Article 12(3) of the India-Singapore-DTAA.
The claim of the revenue more or less is that transaction of sale of computer software to its customers implicit involved making of multiple copies of the software clearly
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