Software Payments Not Royalty: Delhi Court Upholds SC Ruling

CIT Vs Mol Corporation (Delhi High Court)

The Delhi High Court has dismissed a series of Income Tax Appeals filed by the Commissioner of Income Tax (CIT) against MOL Corporation, reinforcing the legal position that payments for the use or resale of computer software do not constitute royalty income taxable in India. The common order, delivered on February 14, 2022, by the Income Tax Appellate Tribunal (ITAT) in ITA No.6194/Del/2018, ITA No.6195/Del/2018, ITA No.6196/Del./2018, and ITA No.6197/Del/2018, had been challenged by the revenue.

During the court proceedings, legal c

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