Case Law Details
Case Name : Moogsoft Inc. Vs CIT (ITAT Delhi)
Appeal Number : ITA No. 9823/Del/2019
Date of Judgement/Order : 17/02/2023
Related Assessment Year : 2016-2017
Courts :
All ITAT ITAT Delhi
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Moogsoft Inc. Vs CIT (ITAT Delhi)
ITAT Delhi held that amount received from sale of software (i.e. copyrighted article) cannot be treated as royalty under Article 12(3) of India-USA DTAA.
Facts- The solitary issue arising for c
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