Right to use software in respect of copyrights falls within mischief of royalty

HIGH COURT OF KARNATAKA CIT, International taxation v. Rational Software Corpn. (India) Ltd. IT APPEAL NO. 3082 OF 2005 March 1, 2012 JUDGMENT 1. The revenue has preferred this appeal against the order passed by the Tribunal which has granted relief to the assessee. 2. In fact, the substantial question of law which arises for consideration in this appeal arose for consideration before this court in two appeals, firstly, in the case of CIT v. Synopsis International Old Ltd. in IT Appeal No s.11 to 15/2008 decided on 3.8.2010 where the substantial question of law was as under: &...