Case Law Details
Case Name : IBM Singapore Pte Ltd. Vs DCIT (ITAT Banglore)
Related Assessment Year : 2014-15
Courts :
All ITAT ITAT Bangalore
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IBM Singapore Pte Ltd. Vs DCIT (ITAT Banglore)
As per the decision rendered by Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt. Ltd., sale proceeds received by the assessee on sale of software licenses cannot be categorized as “Royalty” within the meaning of provisions of DTAA.
FULL TEXT OF THE ORDER OF ITAT BANGALORE
These cross appeals are directed against the order dated 28.9.2018 passed by Ld. CIT(A)-12, Ban
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