Engineering Analysis Centre of Excellence (P) Ltd. v. CIT

432 ITR 471Supreme Court of India2021#50 most cited

What is Engineering Analysis Centre of Excellence (P) Ltd. v. CIT authority for?

Payments for the supply or use of computer software, where there is no transfer of copyright but only a right to use the copyrighted product, are generally considered business profits and not 'royalty' or 'fees for technical services' under the Income Tax Act, 1961 or relevant DTAAs. This principle also applies to transponder fees, which are not taxable as royalty.

914

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2012 to 2026.

Also referred to as

Engineering Analysis Centre of Excellence · computer software royalty · section 9(1)(vi) · DTAA · fees for technical services · copyright transfer · copyrighted article · withholding tax · business profits · section 195 · transponder fees · taxability in India

Also reported as

125 Taxmann.com 42281 Taxmann 19

Sections most often in play

Section 143(3)Section 1961Section 9(1)(vi)Section 234BSection 195Section 90Section 144C(13)Section 9(1)(vii)
Read the full judgment

Issues it is cited on

copyrighted articlesection 14(a)section 9(1)(vi)make available clausecomputer softwaresection 195(2)section 90(2)royalty incomewithholding taxforeign tax creditfees for included servicestax treaty

Judgments citing Engineering Analysis Centre of Excellence (P) Ltd. v. CIT

Finastra International Financial Systems Pte Ltd., Singapore vs. ACIT Circle 1(3)(1) International Tax, New Delhi

In the result, the appeal of the assessee is allowed

ITA 915/DEL/2023[2020-21]Status: DisposedITAT Delhi02 Jan 2024AY 2020-21

Bench: Shri Challa Nagendra Prasad & Dr. B. R. R. Kumar

For Appellant: Sh. Suryanarayan, Sr. AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144CSection 9(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI Before Shri Challa Nagendra Prasad, Judicial Member & Dr. B. R. R. Kumar, Accountant Member ITA No. 915/Del/2023 : Asstt. Year: 2020-21 Finastra International Financial Vs The ACIT(International Taxation), Systems PTE Ltd., Circle-1(3)(1), Delhi 5, Shenton Way, 12-01/04, UIC Building, Singapore 068808 (APPELLANT) (RESPONDENT) PAN No. AAICM 2959 D Assessee by : Sh. Suryanarayan, Sr. Adv. Ms. Mansa, Adv. Revenue by : Sh. Vizay B. Vasanta, CIT-DR Date of Hearing: 01.01.2024 Date of Pronouncement: 02.01.2024 ORDER Per Dr. B. R. R. Kumar:- The present a…

Cadmatic Oy, Mumbai vs. ACIT International, Circle 2(1)(1), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 567/MUM/2023[2020-21]Status: DisposedITAT Mumbai29 Dec 2023AY 2020-21

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Jitendra SinghFor Respondent: Shri Anil Sant
Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 195

…8,333/- in the hands of the appellant and the same may be deleted. 4. The AO failed to appreciate that the appellant's claim is supported by the decision of Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P.) Ltd vs. CIT [2021] 432 ITR 471 (SC) wherein it has been held that the amounts paid by resident Indian Company to non-resident computer software manufacturers/suppliers, as consideration for the resale/use of the computer software is not the payment of royalty for the use of copyright in the computer software, and that the same does not give rise to any income taxable in India.…

Volvo Information Technology Ab, Sweden vs. DCIT Int. Tax. Circle -3(1)(1), New Delhi

In the result, assessee’s appeals in ITA No

ITA 2780/DEL/2022[2015-16]Status: DisposedITAT Delhi20 Dec 2023AY 2015-16

Bench: Shri Kul Bharat & Dr. B.R.R. Kumar

Section 194CSection 9(1)(vi)

…1 ITA No. 393/Del/2018 & 2780/Del/2022 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND DR. B.R.R. KUMAR, ACCOUNTANT MEMBER ITA No. 393/DEL/2018 : (A.Y. 2014-15) & ITA No. 2780/DEL/2022; (A.Y. 2015-16) Volvo Information Technology AB, Vs DCIT, International Taxation, Sweden Circle-3(1)(1), New Delhi. 65/2, 6th Floor, Bagmane Parin, Bagmane Tech Park, CV Raman Nagar, Bengaluru-560093. PAN- AADCV2382G APPELLANT RESPONDENT Assessee represented by Sh. Ajay Vohra, Sr. Adv.; Ms. Somya Jain, Ms. Shaily Gupta; & Sh. Archit Kabra. Department represented by Sh.…

Volvo Information Technology Ab, Sweden vs. DCIT, Intl. Taxation, Circle- 3(1)(1), New Delhi

In the result, assessee’s appeals in ITA No

ITA 393/DEL/2018[2014-15]Status: DisposedITAT Delhi20 Dec 2023AY 2014-15

Bench: Shri Kul Bharat & Dr. B.R.R. Kumar

Section 194CSection 9(1)(vi)

…1 ITA No. 393/Del/2018 & 2780/Del/2022 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND DR. B.R.R. KUMAR, ACCOUNTANT MEMBER ITA No. 393/DEL/2018 : (A.Y. 2014-15) & ITA No. 2780/DEL/2022; (A.Y. 2015-16) Volvo Information Technology AB, Vs DCIT, International Taxation, Sweden Circle-3(1)(1), New Delhi. 65/2, 6th Floor, Bagmane Parin, Bagmane Tech Park, CV Raman Nagar, Bengaluru-560093. PAN- AADCV2382G APPELLANT RESPONDENT Assessee represented by Sh. Ajay Vohra, Sr. Adv.; Ms. Somya Jain, Ms. Shaily Gupta; & Sh. Archit Kabra. Department represented by Sh.…

Synamedia Limited, United Kingdom vs. Assistant Commissioner of Income Tax, International Taxation, Circle 1(2), Bengaluru

In the result, appeal of the assessee is allowed

ITA 940/BANG/2023[2021-22]Status: DisposedITAT Bangalore13 Dec 2023AY 2021-22

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

For Appellant: Shri Rajgopal, A.RFor Respondent: Shri Jeetendra Kumar, D.R

…IT(IT)A No.940/Bang/2023 Synamedia Limited, United Kingdom IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. MADHUMITA ROY, JUDICIAL MEMBER IT(IT)A No.940/Bang/2023 Assessment Year: 2021-22 Synamedia Limited One London Road Staines Upon Thames ACIT London International Taxation Vs. Middlesex, TW 18 4 EX Circle-1(2) United Kingdom Bangalore PAN NO : AABCN2524L APPELLANT RESPONDENT S.P. No.41/Bang/2023 (Arising out of IT(IT)A No.940/Bang/2023) Assessment Year: 2021-22 Synamedia Limited ACIT United Kingdom International Taxation Vs. Circle-1(…

ACIT, Circle-2(2), International Taxation, New Delhi vs. Newspage Pvt Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1992/DEL/2022[2012-13]Status: DisposedITAT Delhi08 Dec 2023AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.1992/Del/2022 िनधा"रणवष"/Assessment Year:2012-13 बनाम Acit, Newspage Pvt. Ltd., Circle 2(2), Vs. C/O Accenture Solutions P. Ltd., International Taxation, Godrej & Boyce Complex, New Delhi. Lbs Marg, Vikhrali West, Mumbai, Maharashtra. Pan No.Aadcn2660H अपीलाथ" Appellant ""यथ"/Respondent

Section 139(5)Section 148Section 246

…I.T.A.No.1992/Del/2022 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D” NEW DELHI BEFORE SHRI G.S. PANNU, HON’BLE VICE PRESIDENT AND SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER आ.अ.सं/.I.T.A No.1992/Del/2022 िनधा"रणवष"/Assessment Year:2012-13 बनाम ACIT, Newspage Pvt. Ltd., Circle 2(2), Vs. C/o Accenture Solutions P. Ltd., International Taxation, Godrej and Boyce Complex, New Delhi. LBS Marg, Vikhrali West, Mumbai, Maharashtra. PAN No.AADCN2660H अपीलाथ" Appellant ""यथ"/Respondent Revenue by Shri Sanjay Kumar, Sr. DR Assessee by Shri Nikhil Tiwari, CA सुनवाईक"तारीख/ Date of hearing: 13.09.2023 08.12.2023 उ"…

Deputy Commissioner of Income Tax, Circle-2(2)(1), Bangalore vs. Devesh Mohan Nayel, Bangalore

In the result, the appeal is allowed

ITA 740/BANG/2023[2019]Status: DisposedITAT Bangalore05 Dec 2023

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2019-20 Dcit, Vs. Shri. Devesh M Nayel, Circle – 2(2)(1), 301, Rennaisance Regalia 95, Main Road, 15Th Cross, Bengaluru. Malleshwaram, Malleshwaram S.O, Bengaluru North, Bengaluru – 560 003. Pan : Aespn 6617 E Appellant Respondent Assessee By : Shri. Veerabasavana Gowda S, Ca Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 04.12.2023 Date Of Pronouncement : 05.12.2023

For Appellant: Shri. Veerabasavana Gowda S, CAFor Respondent: Shri. V. Parithivel, JCIT(DR)(ITAT), Bengaluru
Section 139Section 139(1)Section 143(1)Section 250Section 90

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment Year : 2019-20 DCIT, Vs. Shri. Devesh M Nayel, Circle – 2(2)(1), 301, Rennaisance Regalia 95, Main Road, 15th Cross, Bengaluru. Malleshwaram, Malleshwaram S.O, Bengaluru North, Bengaluru – 560 003. PAN : AESPN 6617 E APPELLANT RESPONDENT Assessee by : Shri. Veerabasavana Gowda S, CA Revenue by : Shri. V. Parithivel, JCIT(DR)(ITAT), Bengaluru. Date of hearing : 04.12.2023 Date of Pronouncement : 05.12.2023 O R D E R Per George George K, Vice President: T…

Commissioner of Income Tax - International Taxation -1 vs. Ericsson, Ab Sweden

ITA - 679 / 2023HC Delhi04 Dec 2023

…ty under the Act and India -Sweden DTAA?” 10. Mr. Bhatia submits that he cannot but accept that the proposed question of law no.(ii) is covered by the decision of the Supreme Court rendered in Engineering Analysis Center of Excellence Pvt. Ltd. v. CIT, 2021 SCC OnLine SC 159. However, as regards the proposed question of law no.(i), Mr Bhatia contends that the CIT(A) has delved into facts which ought to have established that the respondent/assessee had a fixed place PE ITA 679/2023 & connected appeals page 3 of 4 This is a digitally signed order. The authenticity of the order can be re-veri…

Commissioner of Income Tax - International Taxation -1 vs. Ericsson, Ab Sweden

ITA - 684 / 2023HC Delhi04 Dec 2023

…ty under the Act and India -Sweden DTAA?” 10. Mr. Bhatia submits that he cannot but accept that the proposed question of law no.(ii) is covered by the decision of the Supreme Court rendered in Engineering Analysis Center of Excellence Pvt. Ltd. v. CIT, 2021 SCC OnLine SC 159. However, as regards the proposed question of law no.(i), Mr Bhatia contends that the CIT(A) has delved into facts which ought to have established that the respondent/assessee had a fixed place PE ITA 679/2023 & connected appeals page 3 of 4 This is a digitally signed order. The authenticity of the order can be re-veri…

Commissioner of Income Tax (International Taxation)-2 vs. Kony Inc

ITA/669/2023HC Delhi30 Nov 2023

Bench: The Tribunal Are Reflected In The Questions Of Law Put Forward In The Instant Appeal. For Convenience, The Proposed Questions Of Law Are Set Forth Hereafter: (First Issue) (I) Whether On The Facts & Circumstances Of The Case, The Ld. Itat Erred In Holding That Consideration Received For Granting Rights To The Customers Under Eula To Use The Software Is Not Table As Royalty Both Under Section 9(1)(Vi) Of The Act & Under Article 12 Of India-Usa Digitally Signed By:Atul Jain Signing Date:08.12.2023 11:22:22 Signature Not Verified

Section 9(1)(vi)Section 9(1)(vii)

…rned, the same could not be treated as royalty as no copyright in the product was transferred to the customers. 5.1 This view was founded on the decision of the Supreme Court rendered in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, (2021) 432 ITR 471 (SC). Digitally Signed By:ATUL JAIN Signing Date:08.12.2023 11:22:22 Signature Not Verified ITA No.669/2023 Page 3 of 5 5.2 We may also note that the Tribunal has returned a finding of fact that End User Licences issued by the respondent/assessee to…

Commissioner of Income Tax (International Taxation)-2 vs. Kony Inc

ITA-669/2023HC Delhi30 Nov 2023

Bench: The Tribunal Are Reflected In The Questions Of Law Put Forward In The Instant Appeal. For Convenience, The Proposed Questions Of Law Are Set Forth Hereafter: (First Issue) (I) Whether On The Facts & Circumstances Of The Case, The Ld. Itat Erred In Holding That Consideration Received For Granting Rights To The Customers Under Eula To Use The Software Is Not Table As Royalty Both Under Section 9(1)(Vi) Of The Act & Under Article 12 Of India-Usa Digitally Signed By:Atul Jain Signing Date:08.12.2023 11:22:22 Signature Not Verified

Section 9(1)(vi)Section 9(1)(vii)

…rned, the same could not be treated as royalty as no copyright in the product was transferred to the customers. 5.1 This view was founded on the decision of the Supreme Court rendered in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, (2021) 432 ITR 471 (SC). Digitally Signed By:ATUL JAIN Signing Date:08.12.2023 11:22:22 Signature Not Verified ITA No.669/2023 Page 3 of 5 5.2 We may also note that the Tribunal has returned a finding of fact that End User Licences issued by the respondent/assessee to…

Narendra Nath Ratnakaram, Bangalore- Maratahalli vs. Commissioner of Income Tax, Circle-5(3)(2), Ministry of Finance, Income Tax Department

In the result appeal filed by assessee stands allowed for statistical purposes

ITA 508/BANG/2023[2020-21]Status: DisposedITAT Bangalore20 Nov 2023AY 2020-21

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21 Shri Narendranath Ratnakaram, The Deputy L-1-19, Paramount Commissioner Of Raghavendra, Income Tax, 42/6, Varthur Road, Circle – 5(3)(2), Marathahalli, Vs. Bangalore. Bangalore – 560 037. Pan: Aeepr8524A Appellant Respondent Assessee By : Ms. Adam Kajabee, Ca Revenue By : Shri Parithivel, Jcit Dr Date Of Hearing : 20-11-2023 Date Of Pronouncement : 20-11-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 19/12/2022 Passed By National Faceless Appeal Centre (Nfac), Delhi For Assessment Year 2020-21 On Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case, The Order Of The Learned Cit (Appeals) Is Erroneous & Against The Provisions Of The Income Tax Act & Prejudicial To The Appellant. 2. The Learned Cit (Appeals) Has Erred By Passing Order U/S. 250 Without Giving Reasonable Opportunity Of Being

For Appellant: Ms. Adam Kajabee, CAFor Respondent: Shri Parithivel, JCIT DR
Section 139(1)Section 250Section 80ASection 90

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment Year : 2020-21 Shri Narendranath Ratnakaram, The Deputy L-1-19, Paramount Commissioner of Raghavendra, Income Tax, 42/6, Varthur Road, Circle – 5(3)(2), Marathahalli, Vs. Bangalore. Bangalore – 560 037. PAN: AEEPR8524A APPELLANT RESPONDENT Assessee by : Ms. Adam Kajabee, CA Revenue by : Shri Parithivel, JCIT DR Date of Hearing : 20-11-2023 Date of Pronouncement : 20-11-2023 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against t…

Amadeus It Group Sa, Spain vs. ACIT, Circle-1(1)(1) Int.Taxation, New Delhi

In the result, for statistical purposes, the appeal of the assessee is partly allowed

ITA 1742/DEL/2023[2020-21]Status: DisposedITAT Delhi16 Oct 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

For Appellant: Sh. Neeraj Jain &For Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)

…ed on the decision of the Hon’ble Delhi High Court in the case of DIT vs. Rio Tinto Technical Services 340 ITR 507 (Del.). He also referred to the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P.) Ltd. vs. CIT 432 ITR 471 (SC) wherein it has been held that payment for use of software is not in the nature of royalty under the DTAA. Referring to the history and factual matrix of the present case, the Ld. AR submitted that in the assessment framed for AY 2006-07, the assessing officer had substantively brought to tax the booking fee as business income and protectivel…

E Service Singapore Pte Ltd., Gurugram vs. DCIT (International Taxation), New Delhi

In the result, the appeals of the assessee in :

ITA 573/DEL/2017[2013-14]Status: DisposedITAT Delhi10 Oct 2023AY 2013-14

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Satyen Sethi, AdvFor Respondent: Shri Vizay B. Vasanta, CIT- DR
Section 143(3)Section 9(1)(vi)

…irst common grievance is in respect of sale of off the shelf software considered as royalty. 7. This issue is no more res integra as the quarrel has been settled by the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt Ltd 432 ITR 471, which has been followed by this Tribunal in assessee’s own case in A.Ys 2009-10 and 2010-11 in ITA Nos. 3209 & 3210/DEL/2018. The relevant findings read as under: “9.2 We observe, recently the Hon’ble Apex Court in para no 173 of its judgment in the case of Engineering Analysis Centre of Excellence Pvt. Ltd (supra), clearly held that the amoun…

E Service Singapore Pte Ltd., Gurugram vs. DCIT (International Taxation), New Delhi

In the result, the appeals of the assessee in :

ITA 572/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Oct 2023AY 2012-13

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Satyen Sethi, AdvFor Respondent: Shri Vizay B. Vasanta, CIT- DR
Section 143(3)Section 9(1)(vi)

…irst common grievance is in respect of sale of off the shelf software considered as royalty. 7. This issue is no more res integra as the quarrel has been settled by the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt Ltd 432 ITR 471, which has been followed by this Tribunal in assessee’s own case in A.Ys 2009-10 and 2010-11 in ITA Nos. 3209 & 3210/DEL/2018. The relevant findings read as under: “9.2 We observe, recently the Hon’ble Apex Court in para no 173 of its judgment in the case of Engineering Analysis Centre of Excellence Pvt. Ltd (supra), clearly held that the amoun…

Hp Services (Singapore) Pte Ltd., Gurgaon vs. DCIT (International Taxation), New Delhi

In the result, the appeals of the assessee in :

ITA 2142/DEL/2016[2011-12]Status: DisposedITAT Delhi10 Oct 2023AY 2011-12

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Satyen Sethi, AdvFor Respondent: Shri Vizay B. Vasanta, CIT- DR
Section 143(3)Section 9(1)(vi)

…irst common grievance is in respect of sale of off the shelf software considered as royalty. 7. This issue is no more res integra as the quarrel has been settled by the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt Ltd 432 ITR 471, which has been followed by this Tribunal in assessee’s own case in A.Ys 2009-10 and 2010-11 in ITA Nos. 3209 & 3210/DEL/2018. The relevant findings read as under: “9.2 We observe, recently the Hon’ble Apex Court in para no 173 of its judgment in the case of Engineering Analysis Centre of Excellence Pvt. Ltd (supra), clearly held that the amoun…

Ui Path Srl, Delhi vs. ACIT, Circle-1(1)(1) Int.Taxation, Delhi

In the result, the appeal of the assessee in ITA No

ITA 408/DEL/2022[2019-20]Status: DisposedITAT Delhi06 Oct 2023AY 2019-20

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 143(1)Section 234ASection 250

…appreciating the returned position of the appellant that income from distribution I sale of software license is not chargeable to tax in view of the Hon'ble Supreme Court's judgement in case of Engineering Analysis Centre of Excellence Private Limited [2021] 432 ITR 471, and the additional TDS credit claimed during appellate proceedings be allowed as refund since income itself is not chargeable to tax. 5. On the facts and circumstances of the case & in law, the Ld. CIT(A) erred in holding that the appellant did not pursue the relevant deductors to revise their TDS return to include appellant's PAN, thereby resu…

Gunnebo, Mumbai vs. ACIT (International Taxation), Circle-2 (3)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1441/MUM/2021[2016-17]Status: DisposedITAT Mumbai04 Oct 2023AY 2016-17

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 1441/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) Gunnebo Ab Acit (International बिधम/ Po Box No.5181, Goteberg, Taxation), Circle-2(3)(2) Vs. Sweden. Room No.2908, 29Th Floor, World Trade Centre-1, Cuffee Parade, Mumbai-400005. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaecg9613J (अपीलार्थी /Assessee) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Dhanesh Bafna/Pratik Shah/Riddhi Maru Revenue By: Shri Amit Kumar Soni (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 20/07/2023 घोषणा की तारीख /Date Of Pronouncement: 04/10/2023 आदेश / O R D E R

For Appellant: Shri Dhanesh Bafna/PratikFor Respondent: Shri Amit Kumar Soni (Sr. DR)
Section 139Section 14Section 143(3)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI S. RIFAUR RAHMAN, AM आयकर अपील सं/ I.T.A. No. 1441/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) Gunnebo AB ACIT (International बिधम/ PO Box No.5181, Goteberg, Taxation), Circle-2(3)(2) Vs. Sweden. Room No.2908, 29th Floor, World Trade Centre-1, Cuffee Parade, Mumbai-400005. स्थधयी लेखध सं./जीआइआर सं./PAN/GIR No. : AAECG9613J (अपीलार्थी /Assessee) .. (प्रत्यर्थी / Respondent) Assessee by: Shri Dhanesh Bafna/Pratik Shah/Riddhi Maru Revenue by: Shri Amit Kumar Soni (Sr. DR) सुनवाई की तारीख / Date of Hearing: 20/07/…

Softwareone Pte. Ltd., Singapore vs. ACIT, Circle-3(1)(2) Int.Taxation, New Delhi

In the result, appeals are allowed as indicated above

ITA 1840/DEL/2022[2019-20]Status: DisposedITAT Delhi25 Sept 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI BEFORE SHRI SAKTIJIT DEY, VICE-PRESIDENT AND DR. BRR KUMAR, ACCOUNTANT MEMBER ITA Nos. 1839 & 1840/Del/2022 Assessment Years: 2018-19 & 2019-20 SoftwareONE Pte. Ltd., Versus ACIT, Circle 3(1)(2), 233, Mountbatten Road, International Taxation, 02 08 09 10, Singapore Delhi. PAN: AAPCS9237H (Appellant) (Respondent) Assessee by : Ms. Ananya Kapoor, Adv. Revenue by : Sh. Vizay B. Vasanta, CIT-DR Date of hearing : 20.09.2023 Date of pronouncement: 25.09.2023 ORDER Captioned appeals have been filed by the assessee, challenging the final assessment orders…

Softwareone Pte.Ltd., Singapore vs. ACIT, Circle-3(1)(2) Int.Taxation, Delhi

In the result, appeals are allowed as indicated above

ITA 1839/DEL/2022[2018-19]Status: DisposedITAT Delhi25 Sept 2023AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI BEFORE SHRI SAKTIJIT DEY, VICE-PRESIDENT AND DR. BRR KUMAR, ACCOUNTANT MEMBER ITA Nos. 1839 & 1840/Del/2022 Assessment Years: 2018-19 & 2019-20 SoftwareONE Pte. Ltd., Versus ACIT, Circle 3(1)(2), 233, Mountbatten Road, International Taxation, 02 08 09 10, Singapore Delhi. PAN: AAPCS9237H (Appellant) (Respondent) Assessee by : Ms. Ananya Kapoor, Adv. Revenue by : Sh. Vizay B. Vasanta, CIT-DR Date of hearing : 20.09.2023 Date of pronouncement: 25.09.2023 ORDER Captioned appeals have been filed by the assessee, challenging the final assessment orders…