ITAT Bangalore Judgments — August 2021

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that payments for software licenses and database access are not necessarily royalty under DTAA provisions and require re-examination. Similarly, consulting, legal, and other professional fees also need re-examination in light of applicable DTAA provisions.

The Tribunal held that the classification of payments for software and database access as royalty needs re-examination in light of DTAA provisions. Payments for consulting, legal, professional, training, certification, and sub-contracting also require re-examination considering DTAA provisions for Fees for Technical Services.

The Tribunal held that payments for software licenses and database access are not necessarily royalty under DTAA provisions and require re-examination. Similarly, consulting, legal, and other professional fees also need re-examination in light of applicable DTAA provisions.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the classification of payments for software and database access as royalty needs re-examination in light of DTAA provisions. Payments for consulting, legal, professional, training, certification, and sub-contracting also require re-examination considering DTAA provisions for Fees for Technical Services.

The Tribunal held that payments for software licenses and database access are not necessarily royalty under DTAA provisions and require re-examination. Similarly, consulting, legal, and other professional fees also need re-examination in light of applicable DTAA provisions.

The Tribunal held that payments for software licenses and database access are not necessarily royalty under DTAA provisions and require re-examination. Similarly, consulting, legal, and other professional fees also need re-examination in light of applicable DTAA provisions.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the classification of payments for software and database access as royalty needs re-examination in light of DTAA provisions. Payments for consulting, legal, professional, training, certification, and sub-contracting also require re-examination considering DTAA provisions for Fees for Technical Services.

The Tribunal held that the NCLT order and its implications on the income tax dues, in light of the Supreme Court's decision in Ghanashyam Mishra, needed to be examined. Therefore, the matter was restored to the CIT(A) for a fresh decision.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that payments for software licenses and database access are not royalty if they do not grant the right to use copyright. It also directed re-examination of consulting, legal, and professional fees in light of applicable Double Taxation Avoidance Agreements (DTAAs).

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The Tribunal held that the classification of payments for software and database access as royalty needs re-examination in light of DTAA provisions. Payments for consulting, legal, professional, training, certification, and sub-contracting also require re-examination considering DTAA provisions for Fees for Technical Services.

The Tribunal held that payments for software licenses and access to databases are not royalty under the relevant Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, professional, training, certification, and sub-contracting fees in light of applicable DTAA provisions.

The tribunal directed the exclusion of E-Zest Solutions Limited and Softsol India Limited from the list of comparables, citing functional dissimilarity and related party transactions respectively. It also held that additions agreed under MAP proceedings are eligible for Section 10A deduction, following its own prior ruling.

The Tribunal held that the issue of whether payments for software, database access, and related services constitute royalty needs re-examination in light of applicable Double Taxation Avoidance Agreements (DTAAs). It also directed re-examination of consulting, legal, and professional fees.