ADIT(IT) v. Baan Global BV: 49 ITR(T) 73 (Mum)

317 ITR 169Reported decision2009#1618 most cited

What is ADIT(IT) v. Baan Global BV: 49 ITR(T) 73 (Mum) authority for?

Payment for subscription-based access to an offshore database containing financial or economic information is not considered 'royalty' under Section 9(1)(vi), as merely making such information available does not amount to 'imparting information concerning industrial, commercial or scientific experience'.

70

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

Baan Global BV · Factset Research Systems · Section 9(1)(vi) · Section 195 · royalty income · database subscription · imparting information · industrial commercial scientific experience · withholding tax · AAR ruling

Sections most often in play

Section 195Section 13(3)Section 143(3)Section 195(2)Section 9(1)(vi)Section 195(1)Section 11(3)(a)Section 13

Issues it is cited on

copyrighted articlesection 195(2)royalty incomewithholding taxsection 9(1)(vi)computer softwaretax treatysection 195section 9(1)section 19double taxationtransfer

Judgments citing ADIT(IT) v. Baan Global BV: 49 ITR(T) 73 (Mum)

DCIT(IT)-2(1)(2),MUMBAI, MUMBAI vs. DELOITTE TOUCH TMATSU INDIA LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4655/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Dec 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DCIT(IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE HASKIN & SELLS LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4654/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Dec 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DCIT(IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE HASKIN & SELLS LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4653/MUM/2025[2020]Status: DisposedITAT Mumbai17 Dec 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DCIT(IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE TOUCH TMATSU INDIA LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4638/MUM/2025[2021]Status: DisposedITAT Mumbai17 Dec 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2 MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 3455/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Dec 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

ASST. COMMISSIONER OF INCOME TAX(IT)-2(1)-2 MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 2723/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Aug 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2019-20

For Appellant: Shri Niraj Sheth and Ms. Darshana Shah, AdvocatesFor Respondent: Shri Krishna Kumar, Sr. DR
Section 195(1)Section 195(2)Section 9(1)(vi)

…ments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAITAX, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 5091/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Mar 2025AY 2019-20
Section 195(2)Section 9(1)(vi)

…are made for the services rendered by\nHoldings / Deloitte Services and, therefore, they cannot be regarded as\nconsideration for imparting any information concerning industrial,\ncommercial or scientific experience.\n\nC. Factset Research Systems Inc. In re 317 ITR 169 (AAR)\nThe Applicant maintained a database which was located outside India\nand which contained financial and economic information including\nfundamental data of a large number of companies worldwide. The said\ninformation was made available to customers on a subscription basis.\nThe question arose whether such a payment could be regarded as\npay…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 5089/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Mar 2025AY 2019-20
Section 195(2)Section 9(1)(vi)

…s are made for the services rendered by\nHoldings / Deloitte Services and, therefore, they cannot be regarded as\nconsideration for imparting any information concerning industrial,\ncommercial or scientific experience.\nC.\nFactset Research Systems Inc. In re 317 ITR 169 (AAR)\nThe Applicant maintained a database which was located outside India\nand which contained financial and economic information including\nfundamental data of a large number of companies worldwide. The said\ninformation was made available to customers on a subscription basis.\nThe question arose whether such a payment could be regarded as\npay…

DCIT(IT)-2(1)-2, MUMBAI, MUMBAI vs. DELOITTE HASKINS & SELLS LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 5715/MUM/2024[2019-20]Status: DisposedITAT Mumbai18 Feb 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 195Section 195(1)Section 195(2)Section 9(1)(vi)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) 12 Deloitte Haskins & Sells LLP The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payme…

DCIT (IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE HASKINS SELLS LLP, UK

In the result, all the appeals of the assessees are allowed

ITA 4517/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar, Sr. DR
Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DCIT (IT)-2(1)(2),MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, UK

In the result, all the appeals of the assessees are allowed

ITA 4515/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar, Sr. DR
Section 195(2)

…yments are made for the services rendered by Holdings / Deloitte Services and, therefore, they cannot be regarded as consideration for imparting any information concerning industrial, commercial or scientific experience. c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

THE DY.CIT (INT.-TAXA.)-1, , AHMEDABAD vs. ZYDUS LIFSCIENCE LTD. (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.), AHMEDABAD

In the result, the appeal of the revenue is hereby dismissed

ITA 36/AHD/2021[2012-13]Status: DisposedITAT Ahmedabad17 May 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

For Appellant: Shri Jigar Patel, A.RFor Respondent: Shri Sudhakar Verma, Sr. D.R
Section 9(1)(vi)Section 9(1)(vii)

…pellant or designed to its requirements and that there is no element of any royalty and therefore, the question of deduction of withholding tax on such payments u/s. 195 of the I.T. Act does not arise. The appellant as relied on Factset Research Systems Inc., 317 ITR 169 (AAR) and Dun & Bradstreet Espana, S.A., 272 ITR 99 (AAR). The appellant has also drawn attention to on the Order of the Hon'ble ITAT Ahmedabad, in the appellant's own case for A.Y. 2010- 11, wherein, in respect of identical payments, the Hon'ble ITAT held that "the treaty provision unambiguously requires that only when the use is of the copyrigh…

PLURALSIGHT LLC,UTAH vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), BANGALORE

In the result, appeal filed by the assessee is allowed

ITA 639/BANG/2023[2020-21]Status: DisposedITAT Bangalore02 Jan 2024AY 2020-21

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Shri Aliasgar Rampurwala, C.AFor Respondent: Shri Praveen Karanth, CIT(DR)
Section 143(3)Section 144(1)Section 144CSection 144C(13)Section 144C(5)Section 234ASection 234BSection 24Section 9(1)(vi)

…technique or methodology employed in evolving databases with the users, nor imparts any information relating to them.” (emphasis supplied) 18. On similar facts as that of the assessee, the Hon’ble AAR in the case of Factset Research Systems Inc., reported in 317 ITR 169 (AAR) had held as under in Para 11 of the ruling: “11. The learned Departmental Representative then invoked clause (iv) of Explanation 2 which speaks of "imparting any information concerning technical, industrial, commercial or scientific knowledge, experience or skill". The DTAA (Article Page 15 of 17 12.3) uses slightly different language. It…

M/S. PLURALSIGHT LLC,UNITED STATES OF AMERICA vs. DCIT ASMT, CIRCLE-2(1), BENGALURU

In the result, appeal filed by the assessee is allowed

ITA 37/BANG/2023[2016-17]Status: DisposedITAT Bangalore21 Aug 2023AY 2016-17

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2016-17 M/S. Pluralsight Llc, Dcit, 182N Union Avenue, Farmington, Asmt, Utah, Foreign, Vs. Circle – 2(1), United States. Bengaluru. Pan : Aahcp 5337 K Appellant Respondent Assessee By : Shri. Dhanesh Bafna, Ca Revenue By : Dr. Satyasai Rath, Cit(Dr), Itat, Bengaluru. Date Of Hearing : 16.08.2023 Date Of Pronouncement : 21.08.2023

For Appellant: Shri. Dhanesh Bafna, CAFor Respondent: Dr. Satyasai Rath, CIT(DR), ITAT, Bengaluru
Section 143Section 143(2)Section 250Section 9(1)(vi)

…thodology employed in Page 14 of 17 evolving databases with the users, nor imparts any information relating to them.” (emphasis supplied) 18. On similar facts as that of the assessee, the Hon’ble AAR in the case of Factset Research Systems Inc., reported in 317 ITR 169 (AAR) had held as under in Para 11 of the ruling: “11. The learned Departmental Representative then invoked clause (iv) of Explanation 2 which speaks of "imparting any information concerning technical, industrial, commercial or scientific knowledge, experience or skill". The DTAA (Article 12.3) uses slightly different language. It speaks of paym…

SPRINGER NATURE CUSTOMER SERVICES CENTRE GMBH,NEW DELHI vs. JCIT, INTERNATIONALO TAXATION, CIRCLE-3(1)(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 2534/DEL/2019[2013-14]Status: DisposedITAT Delhi14 Oct 2022AY 2013-14

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2013-14] Springer Nature Customer Services Vs Jcit Centre Gmbh (Earlier Known As (International Taxation), Springer Customer Centre Gmbh), Circle-3(1)(2), 7Th Floor, Vijaya Building, New Delhi. 17-Barakhamba Road, New Delhi-110001. Pan-Aascs1092B Appellant Respondent Appellant By S/Shri Himanshu Sinha, Bhuwan Dhooper & Vibhu Gupta, Advocates Respondent By Ms. Rashmita Jha, Cit Dr Date Of Hearing 20.09.2022 Date Of Pronouncement 14.10.2022

Section 143(3)Section 234ASection 234BSection 271Section 9(1)(vi)

…er BV, In re [2021] 432 ITR 251 (AAR - Mumbai) • HEG Ltd. (2003) 263 ITR 230 (MP) • Dun and Bradstreet Information Services India P. Ltd. (2012) 338 ITR 95 (Bom.) • GVK Oil & Gas Ltd. (2016) 68 taxmann.com 134 (Hyd.) • Factset Research Systems Inc. (2009) 317 ITR 169 (AAR) 3.9 Applying the same principle to the facts of the present case, it is submitted that the subscription fees collected by the Appellant is not taxable as royalty under the Act as well as under the Tax Treaty. 3.10 Without prejudice to the above, it is respectfully submitted the Appellant was collecting subscription fee from third-party end…

DELOITTE HASKINS & SELLS LLP,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-2(1)(2), MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 233/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Jul 2022AY 2019-20

Bench: Shri Pramod Kumar & Shri Amit Shuklaita Nos.201 To 233/Mum/2021, : A.Ys : 2018-19 & 4800 To 4804/Mum/2019 & 2019-20 4810 To 4814/Mum/2019 Deloitte Haskins & Sells Llp Vs. Deputy Commissioner One International Center, Of Income Tax, (It) - Tower 3, 27Th - 32Nd Floor, 2(1)(2) Senapati Bapat Marg, Mumbai 400021 Elphinstone Road, (W) Mumbai 400013 [Pan: Aacfd4815A] Ita Nos. 4744, 4775 To : A.Y : 2018-19 4782/Mum/2019 Deloitte Touche Tohmatsu Vs. Deputy Commissioner India Llp, Of Income Tax, (It) - Indiabulls Finance Centre 2(1)(2) Tower 3, 27Th-32Nd Floor, Mumbai 400021 Senapati Bapat Marg, Elphinstone Road, (W) Mumbai 400013 [Pan: Aalfd7157J]

For Appellant: Shri P.J PardiwalaFor Respondent: Shri Milind Chavan
Section 195

…ion for imparting any information concerning industrial, commercial or scientific experience. 12 Deloitte Haskins & Sells LLP & Anr. ITA Nos. 201 to 233/Mum/2021, 4800 to 4804, 4810 to 4814, 4744, 4775 to 4782/Mum/2019 c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DELOITTE HASKINS & SELLS LLP,MUMBAI vs. DCIT (INTL TAX) -2 (1) (2) , MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 232/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Jul 2022AY 2019-20

Bench: Shri Pramod Kumar & Shri Amit Shuklaita Nos.201 To 233/Mum/2021, : A.Ys : 2018-19 & 4800 To 4804/Mum/2019 & 2019-20 4810 To 4814/Mum/2019 Deloitte Haskins & Sells Llp Vs. Deputy Commissioner One International Center, Of Income Tax, (It) - Tower 3, 27Th - 32Nd Floor, 2(1)(2) Senapati Bapat Marg, Mumbai 400021 Elphinstone Road, (W) Mumbai 400013 [Pan: Aacfd4815A] Ita Nos. 4744, 4775 To : A.Y : 2018-19 4782/Mum/2019 Deloitte Touche Tohmatsu Vs. Deputy Commissioner India Llp, Of Income Tax, (It) - Indiabulls Finance Centre 2(1)(2) Tower 3, 27Th-32Nd Floor, Mumbai 400021 Senapati Bapat Marg, Elphinstone Road, (W) Mumbai 400013 [Pan: Aalfd7157J]

For Appellant: Shri P.J PardiwalaFor Respondent: Shri Milind Chavan
Section 195

…ion for imparting any information concerning industrial, commercial or scientific experience. 12 Deloitte Haskins & Sells LLP & Anr. ITA Nos. 201 to 233/Mum/2021, 4800 to 4804, 4810 to 4814, 4744, 4775 to 4782/Mum/2019 c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DELOITTE HASKINS & SELLS LLP,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-2(1)(2), MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 231/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Jul 2022AY 2019-20

Bench: Shri Pramod Kumar & Shri Amit Shuklaita Nos.201 To 233/Mum/2021, : A.Ys : 2018-19 & 4800 To 4804/Mum/2019 & 2019-20 4810 To 4814/Mum/2019 Deloitte Haskins & Sells Llp Vs. Deputy Commissioner One International Center, Of Income Tax, (It) - Tower 3, 27Th - 32Nd Floor, 2(1)(2) Senapati Bapat Marg, Mumbai 400021 Elphinstone Road, (W) Mumbai 400013 [Pan: Aacfd4815A] Ita Nos. 4744, 4775 To : A.Y : 2018-19 4782/Mum/2019 Deloitte Touche Tohmatsu Vs. Deputy Commissioner India Llp, Of Income Tax, (It) - Indiabulls Finance Centre 2(1)(2) Tower 3, 27Th-32Nd Floor, Mumbai 400021 Senapati Bapat Marg, Elphinstone Road, (W) Mumbai 400013 [Pan: Aalfd7157J]

For Appellant: Shri P.J PardiwalaFor Respondent: Shri Milind Chavan
Section 195

…ion for imparting any information concerning industrial, commercial or scientific experience. 12 Deloitte Haskins & Sells LLP & Anr. ITA Nos. 201 to 233/Mum/2021, 4800 to 4804, 4810 to 4814, 4744, 4775 to 4782/Mum/2019 c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DELOITTE HASKINS & SELLS LLP,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-2(1)(2), MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 230/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Jul 2022AY 2019-20

Bench: Shri Pramod Kumar & Shri Amit Shuklaita Nos.201 To 233/Mum/2021, : A.Ys : 2018-19 & 4800 To 4804/Mum/2019 & 2019-20 4810 To 4814/Mum/2019 Deloitte Haskins & Sells Llp Vs. Deputy Commissioner One International Center, Of Income Tax, (It) - Tower 3, 27Th - 32Nd Floor, 2(1)(2) Senapati Bapat Marg, Mumbai 400021 Elphinstone Road, (W) Mumbai 400013 [Pan: Aacfd4815A] Ita Nos. 4744, 4775 To : A.Y : 2018-19 4782/Mum/2019 Deloitte Touche Tohmatsu Vs. Deputy Commissioner India Llp, Of Income Tax, (It) - Indiabulls Finance Centre 2(1)(2) Tower 3, 27Th-32Nd Floor, Mumbai 400021 Senapati Bapat Marg, Elphinstone Road, (W) Mumbai 400013 [Pan: Aalfd7157J]

For Appellant: Shri P.J PardiwalaFor Respondent: Shri Milind Chavan
Section 195

…ion for imparting any information concerning industrial, commercial or scientific experience. 12 Deloitte Haskins & Sells LLP & Anr. ITA Nos. 201 to 233/Mum/2021, 4800 to 4804, 4810 to 4814, 4744, 4775 to 4782/Mum/2019 c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

DELOITTE HASKINS & SELLS LLP,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-2(1)(2), MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 229/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Jul 2022AY 2019-20

Bench: Shri Pramod Kumar & Shri Amit Shuklaita Nos.201 To 233/Mum/2021, : A.Ys : 2018-19 & 4800 To 4804/Mum/2019 & 2019-20 4810 To 4814/Mum/2019 Deloitte Haskins & Sells Llp Vs. Deputy Commissioner One International Center, Of Income Tax, (It) - Tower 3, 27Th - 32Nd Floor, 2(1)(2) Senapati Bapat Marg, Mumbai 400021 Elphinstone Road, (W) Mumbai 400013 [Pan: Aacfd4815A] Ita Nos. 4744, 4775 To : A.Y : 2018-19 4782/Mum/2019 Deloitte Touche Tohmatsu Vs. Deputy Commissioner India Llp, Of Income Tax, (It) - Indiabulls Finance Centre 2(1)(2) Tower 3, 27Th-32Nd Floor, Mumbai 400021 Senapati Bapat Marg, Elphinstone Road, (W) Mumbai 400013 [Pan: Aalfd7157J]

For Appellant: Shri P.J PardiwalaFor Respondent: Shri Milind Chavan
Section 195

…ion for imparting any information concerning industrial, commercial or scientific experience. 12 Deloitte Haskins & Sells LLP & Anr. ITA Nos. 201 to 233/Mum/2021, 4800 to 4804, 4810 to 4814, 4744, 4775 to 4782/Mum/2019 c. Factset Research Systems Inc. In re 317 ITR 169 (AAR) The Applicant maintained a database which was located outside India and which contained financial and economic information including fundamental data of a large number of companies worldwide. The said information was made available to customers on a subscription basis. The question arose whether such a payment could be regarded as payment f…

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