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Software Sale Payment Not Royalty under Indo-Singapore DTAA: Delhi HC
Case Law Details
- Case Name
- CIT - International Taxation Vs DXC Technology Services Singapore Pte. Ltd. (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009-10
- Courts
- All High Courts, Delhi High Court
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CIT – International Taxation Vs DXC Technology Services Singapore Pte. Ltd. (Delhi High Court)
Introduction: The Delhi High Court recently ruled on an appeal filed by CIT – International Taxation-1 against DXC Technology Services Singapore Pte. Ltd. The appeal concerned the Assessment Year 2009-10 and focused on whether payments received for the sale/supply of software could be considered royalty under Article 12(3) of the India-Singapore Double Taxation Avoidance Agreement (DTAA).
Detailed Analysis: The dispute originated from the scrutiny-assessment of the respondent/assessee, le...
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