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 366,470 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

Asia Today Ltd, Mumbai vs. ADIT (It) 2(2), Mumbai

In the result, Assessee's appeal is allowed

ITA 1403/MUM/2008[2004-2005]Status: DisposedITAT Mumbai24 Dec 2025AY 2004-2005

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2004-05 M/S. Asia Today Limited, Asst. Director Of Income C/O. Zee Entertainment Enterprises Tax (International Ltd., Vs. Taxation)-2(2), 135, Dr. Annie Besant Road, Scindia House, Worli, Mumbai – 400 018 Bellard Estate, Pan: Aabca0249F Mumbai - 400039 (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth, Ld. A.R. Revenue By : Shri Krishna Kumar, Ld. Sr. D.R. Date Of Hearing : 10.10.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2007, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2004-05. 2. The Relevant Facts For Adjudication Of This Appeal Are As Under: The Assessee, Being A Foreign Telecasting Company Incorporated In Mauritius & Having Tax Residency Certificate Of Mauritius , During The Ay Under Consideration Was Engaged In The Production & Acquiring Rights Of Various Television Films Including Feature Films, As A Copy Right Owner/Holder Of Various Hindi Feature Films Produced & Censored In India, As Mentioned In Schedule ‘C’ Annexed With The ‘Agreement Of 2 M/S Asia Today Ltd. Vs Asst. Dit (Int. Taxation)-2(2)

For Appellant: Shri Niraj Sheth, Ld. A.RFor Respondent: Shri Krishna Kumar, Ld. Sr. D.R
Section 250Section 9(1)(vi)

…ed no right with respect to copyright upon the Indian entities. This aspect, in any case, is liable to be answered in favour of the assessee bearing in mind the decision of the Supreme Court in Engineering Analysis Centre of Excellence (P). Ltd. v. CIT [2021] 432 ITR 471/[2022] 3 SCC 321 and which had clearly held and recognized the distinction between a broadcasting right and a copyright as flowing from Sections 14 and 37 of the Copyright Act, 1957. This quite apart from the undisputed fact that insofar as the present respondent is concerned, even the question of broadcasting rights does not arise since it was i…

Asia Satellite Telecommunications Company Limited, Hong Kong vs. Assistant Commissioner of Income Tax Circle Int Tax 1(1)(1), Delhi, Civic Centre, Minto Road, New Delhi

In the result, appeal of the assessee for AY 2020-21 is partly allowed

ITA 2674/DEL/2023[2021-2022]Status: DisposedITAT Delhi19 Dec 2025AY 2021-2022

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2353 और 2674/धिल्ली/2023(नि.व. 2020-21 और 2021-22)

For Appellant: S/Shri Ajay Vohra, Sr. Advocate with Aditya Vohra & Tanmay Dhakras, AdvocatesFor Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(3)Section 9(1)(vi)

…hus, the fee charged by the assessee for providing access to satellite transmission services is not taxable as royalty in India. The ld. Counsel pointed that the Hon’ble Supreme Court of India in the case of Engineering Analysis Centre of Excellence (P) Ltd., 432 ITR 471 has affirmed the decision rendered in the case of DIT vs. New Skies Satellite BV (supra). 7. Per contra, the ld. DR vehemently supported the impugned order. The ld. DR filed his written submissions, the same are reproduced hereunder: - “The assessee, a Hong Kong-based entity, contends that transponder fees are not taxable as "Royalty" under the…

Asia Satellite Telecommunications Company Limited, Hongkong vs. ACIT Circle Intl. Taxation 1(1)(1), New Delhi

In the result, appeal of the assessee for AY 2020-21 is partly allowed

ITA 2353/DEL/2023[AY 2020-2021]Status: DisposedITAT Delhi19 Dec 2025

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2353 और 2674/धिल्ली/2023(नि.व. 2020-21 और 2021-22)

For Appellant: S/Shri Ajay Vohra, Sr. Advocate with Aditya Vohra & Tanmay Dhakras, AdvocatesFor Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(3)Section 9(1)(vi)

…hus, the fee charged by the assessee for providing access to satellite transmission services is not taxable as royalty in India. The ld. Counsel pointed that the Hon’ble Supreme Court of India in the case of Engineering Analysis Centre of Excellence (P) Ltd., 432 ITR 471 has affirmed the decision rendered in the case of DIT vs. New Skies Satellite BV (supra). 7. Per contra, the ld. DR vehemently supported the impugned order. The ld. DR filed his written submissions, the same are reproduced hereunder: - “The assessee, a Hong Kong-based entity, contends that transponder fees are not taxable as "Royalty" under the…

DCIT(It)-2(1)(2), 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)

…ssessing Officer has simply referred to certain decisions (cited supra) and held them to be in the nature of Royalty. 7. Mr. Percy Pardiwala submitted that now the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. vs CIT, 432 ITR 471 has reversed the view taken in the various decisions which have been relied upon by the Assessing Officer in coming to the contention that the payments were in the nature of Royalty. He further submitted that the Assessing Officer has heavily relied upon decision of the AAR in the case of EY Global Services Ltd., which was heavily relied upon by…

DCIT(It)-2(1)(2), 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)

…ssessing Officer has simply referred to certain decisions (cited supra) and held them to be in the nature of Royalty. 7. Mr. Percy Pardiwala submitted that now the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. vs CIT, 432 ITR 471 has reversed the view taken in the various decisions which have been relied upon by the Assessing Officer in coming to the contention that the payments were in the nature of Royalty. He further submitted that the Assessing Officer has heavily relied upon decision of the AAR in the case of EY Global Services Ltd., which was heavily relied upon by…

DCIT(It)-2(1)(2), 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)

…ssessing Officer has simply referred to certain decisions (cited supra) and held them to be in the nature of Royalty. 7. Mr. Percy Pardiwala submitted that now the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. vs CIT, 432 ITR 471 has reversed the view taken in the various decisions which have been relied upon by the Assessing Officer in coming to the contention that the payments were in the nature of Royalty. He further submitted that the Assessing Officer has heavily relied upon decision of the AAR in the case of EY Global Services Ltd., which was heavily relied upon by…

DCIT(It)-2(1)(2), 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)

…ssessing Officer has simply referred to certain decisions (cited supra) and held them to be in the nature of Royalty. 7. Mr. Percy Pardiwala submitted that now the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. vs CIT, 432 ITR 471 has reversed the view taken in the various decisions which have been relied upon by the Assessing Officer in coming to the contention that the payments were in the nature of Royalty. He further submitted that the Assessing Officer has heavily relied upon decision of the AAR in the case of EY Global Services Ltd., which was heavily relied upon by…

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)

…ssessing Officer has simply referred to certain decisions (cited supra) and held them to be in the nature of Royalty. 7. Mr. Percy Pardiwala submitted that now the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. vs CIT, 432 ITR 471 has reversed the view taken in the various decisions which have been relied upon by the Assessing Officer in coming to the contention that the payments were in the nature of Royalty. He further submitted that the Assessing Officer has heavily relied upon decision of the AAR in the case of EY Global Services Ltd., which was heavily relied upon by…

Outsystems Singapore Pte. Ltd., Singapore vs. DCIT Circle 2(2)(2) (International Taxation), New Delhi

In the result, appeal of the assessee is allowed

ITA 1601/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Dec 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.1601/धिल्ली/2025(नि.व. 2022-23) Outsytems Singapore Pte. Ltd., 41-01, 8 Temasek Boulevard, Suntec Tower Three, ...... अपीलार्थी/Appellant Singapore 389980 Pan Aadco-0528-P बिाम Vs. The Deputy Commissioner Of Income Tax, Circle International Tax 2(2)(2), Civic Centre, ..... प्रनिवादी/Respondent Minto Road, New Delhi 110002 अपीलार्थी द्वारा/ Appellant By : Shri Ajit Jain & Ms. Shivangi Chitlangia Chartered Accountants प्रधिवािीद्वारा/Respondent By : Ms. Ekta Jain, Cit(Dr) सुिवाई की निथर्थ/ Date Of Hearing : 03/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 10/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act,1961 (Hereinafter Referred To As ‘The Act’) Dated 10.01.2025, For Assessment Year 2022-23. 2. The Assessee In Appeal Has Raised As Many As 13 Grounds. The Ld. Counsel For The Assessee At The Outset Submitted That He Is Not Pressing Ground No. 4 Of Appeal Assailing Validity Of The Assessment Order Without Din. In Light Of The 2 Statement Made By Ld. Counsel For The Assessee, Ground No. 4 Of Appeal Is Dismissed As Not Pressed.

For Appellant: Shri Ajit Jain & Ms. Shivangi ChitlangiaFor Respondent: Ms. Ekta Jain, CIT(DR)
Section 14Section 143(3)

…for licensing of software cannot be treated as FTS as per DTAA. He finally submits that the case of the assessee is squarely covered by the decision of Hon’ble Supreme of Court of India in the case of Engineering Analysis Centre of Excellence P. Ltd. vs CIT, 432 ITR 471. 6. Per contra, Ms. Ekta Jain representing the department vehemently defended validity of the impugned assessment order. The ld. DR placed on record factual report from the AO dated 25.04.2025 explaining the reasons for signing the assessment order manually. The ld. DR further referred to the decision of Cochin Bench of the Tribunal in the case o…

Commissioner of Income Tax, International Taxation-1, New Delhi vs. Clifford Chance Pte Ltd

The appeals are dismissed

ITA/354/2025HC Delhi04 Dec 2025

Bench: Us Is For The Assessment Year (Ay) 2020-21 & I.T.A. 353/2025 Is For Ay 2021-22.

For Appellant: Mr. Puneet Rai, SSC, Mr. Ashvini Kr., MrFor Respondent: Mr. Ajay Vohra, Senior Advocate with Mr
Section 143(3)Section 144C(13)Section 260A

…rmining the existence of permanent establishment in India. Reference in this regard is made to the judgments in the cases of Union of India v. Azadi Bachao Andolan, [2004] 10 SCC 1 (SC); and Engineering Analysis Centre for Excellence (P) Ltd v. CIT, [2021] 432 ITR 471 (SC). It is submitted that notwithstanding the introduction of the concept of Significant Economic Presence through Explanation 2A to Section 9(1)(i) of the Act, unilateral amendments made in the Act cannot override the provisions of the DTAA. To buttress this argument, he has referred to the judgments in DIT v. New Skies Satellite BV, [2016…

Commissioner of Income Tax, International Taxation-1, New Delhi vs. Clifford Chance Pte Ltd

The appeals are dismissed

ITA/353/2025HC Delhi04 Dec 2025

Bench: Us Is For The Assessment Year (Ay) 2020-21 & I.T.A. 353/2025 Is For Ay 2021-22.

For Appellant: Mr. Puneet Rai, SSC, Mr. Ashvini Kr., MrFor Respondent: Mr. Ajay Vohra, Senior Advocate with Mr
Section 143(3)Section 144C(13)Section 260A

…rmining the existence of permanent establishment in India. Reference in this regard is made to the judgments in the cases of Union of India v. Azadi Bachao Andolan, [2004] 10 SCC 1 (SC); and Engineering Analysis Centre for Excellence (P) Ltd v. CIT, [2021] 432 ITR 471 (SC). It is submitted that notwithstanding the introduction of the concept of Significant Economic Presence through Explanation 2A to Section 9(1)(i) of the Act, unilateral amendments made in the Act cannot override the provisions of the DTAA. To buttress this argument, he has referred to the judgments in DIT v. New Skies Satellite BV, [2016…

Thaicom Public Company Ltd, Delhi vs. ACIT, Central Circle Intl Tax-3(1)(1), Delhi

In the result, impugned order is quashed and appeal of the assessee is allowed

ITA 1803/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.1803/िद"ी/2025(िन.व. 2018-19) Thaicom Public Company Ltd., (Earlier Known As Shin Satellite Public Company Ltd.), C/O Mohinder Puri & Co. 1A-D, Vandhna, 11 Tolstoy Marg, New Delhi 110001 ...... अपीलाथ"/Appellant Pan No: Aagcs-4481-E बनाम Vs. Assistant Commissioner Of Income Tax, Circle 3(1)(1), International Taxation, ..... "ितवादी/Respondent New Delhi 11002

For Appellant: Shri Ajay Vohra, Sr. Advocate with S/Shri Jatinder Singh & Akshay MathurFor Respondent: Shri M.S Nethrapal, CIT-DR (Through VC)
Section 143(3)Section 147Section 148ASection 9(1)(vi)

…reasons to offer such receipts in the impugned assessment year to tax. Further, the said judgment of Hon’ble Delhi High Court was later approved by the Hon’ble Supreme Court of India in the case of Engineering Analysis Centre of Excellence (P.) Ltd. vs. CIT, 432 ITR 471 (SC). In the backdrop of facts narrated above, the ld. Counsel for the assessee asserted that reopening of assessment is bad in law as the very basis on which reopening is initiated has already been decided by the Hon’ble High Court in favour of the assessee. To support his arguments, the ld. Counsel placed reliance on the following decisions: …

Pr Commissioner of Income Tax vs. M/S Synamedia Limited

ITA/108/2024HC Karnataka19 Nov 2025

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 260

…- 10 - HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS Engineering Analysis Centre of Excellence Private Limited v. Commissioner of Income Tax And Another [reported in (2021) 432 ITR 471]. It is not in dispute that certain review petitions, which are filed asserting that a review petition as against the decision in Engineering Analysis Centre of Excellence Private Limtied [supra] is pending, are disposed of. In the light of these circumstances, this Court opines that none of the questions proposed are open for consi…

Commissioner of Income Tax, International Taxation-1, Delhi vs. Dxc Technology Services Singapore Pte Ltd. (Earlier Known As Hp Services Singapore Pte Ltd.)

The appeals are dismissed against the

ITA/589/2025HC Delhi10 Nov 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

…ated as royalty within the meaning Article 12(3) of the India Singapore Double Taxation Avoidance Agreement. 5.1. The Tribunal relied upon the judgment of the Supreme Court rendered in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471. 6. Having regard to the findings of fact and the enunciation of law by the Supreme Court in the aforementioned judgment, according to us, the impugned order does not require interference. 7. In our opinion, no substantial question of law arises for consideration. The appeal is, accordingly, closed. 8. Consequently, pending application…

John Wiley & Sons, Inc., United States of America vs. Assistant Commissioner of Income Tax, International Taxation, Circle 2(1)(2), New Delhi, Civic Centre, Minto Road

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

ITA 2029/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23]

Section 143(3)Section 144C(13)Section 153Section 270ASection 9(1)(vi)Section 9(1)(vii)

…ch does not amount to royalty. In this regard, reliance is placed on following decisions, wherein difference between a Copyright and a copyrighted article has been brought out very clearly:  Engineering Analysis Centre of Excellence (P.) Ltd. vs. CIT, [2021] 432 ITR 471 (SC)  CIT vs. ZTE Corporation, [2021] 282 Taxman 304 (SC) dismissed the SLP filed by Revenue. Review Petition filed by the Revenue also dismissed by the Hon’ble Supreme Court (TS-741-SC-2023) 16. Even as per Explanation 2 to the Section 9(1)(vi) of the Act, the impugned receipts from not taxable as royalty. Thus, receipts from Indian customers f…

Commissioner of Income Tax, International Taxation-1, Delhi vs. Dxc Technology Services Singapore Pte Ltd. (Earlier Known As Hp Services Singapore Pte Ltd.)

The appeals are dismissed against the

ITA/574/2025HC Delhi06 Nov 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 143(3)Section 144C

…ated as royalty within the meaning Article 12(3) of the India Singapore Double Taxation Avoidance Agreement. 5.1. The Tribunal relied upon the judgment of the Supreme Court rendered in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471. Signed By:PRADEEP SHARMA Signing Date:04.12.2025 10:40:39 Signature Not Verified ITA 581/2025 & connected Page 4 of 9 6. Having regard to the findings of fact and…

Commissioner of Income Tax, International Taxation-1, Delhi vs. Dxc Technology Services (Singapore) Pte Ltd. (Earlier Known As Hp Services (Singapore) Pte Ltd.)

The appeals are dismissed against the

ITA/581/2025HC Delhi06 Nov 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 143(3)Section 144C

…ated as royalty within the meaning Article 12(3) of the India Singapore Double Taxation Avoidance Agreement. 5.1. The Tribunal relied upon the judgment of the Supreme Court rendered in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471. Signed By:PRADEEP SHARMA Signing Date:04.12.2025 10:40:39 Signature Not Verified ITA 581/2025 & connected Page 4 of 9 6. Having regard to the findings of fact and…

Commissioner of Income Tax, International Taxation-1, Delhi vs. Dxc Technology Services Singapore Pte Ltd. (Earlier Known As Hp Services Singapore Pte Ltd.)

The appeals are dismissed against the

ITA/582/2025HC Delhi06 Nov 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 143(3)Section 144C

…ated as royalty within the meaning Article 12(3) of the India Singapore Double Taxation Avoidance Agreement. 5.1. The Tribunal relied upon the judgment of the Supreme Court rendered in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471. Signed By:PRADEEP SHARMA Signing Date:04.12.2025 10:40:39 Signature Not Verified ITA 581/2025 & connected Page 4 of 9 6. Having regard to the findings of fact and…

Commissioner of Income Tax, International Taxation-1, Delhi vs. Dxc Technology Services (Singapore) Pte Ltd. (Earlier Known As Hp Services (Singapore) Pte Ltd.)

The appeals are dismissed against the

ITA - 581 / 2025HC Delhi06 Nov 2025
Section 143(3)Section 144C

…ated as royalty within the meaning Article 12(3) of the India Singapore Double Taxation Avoidance Agreement. 5.1. The Tribunal relied upon the judgment of the Supreme Court rendered in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471. Signed By:PRADEEP SHARMA Signing Date:04.12.2025 10:40:39 Signature Not Verified ITA 581/2025 & connected Page 4 of 9 6. Having regard to the findings of fact and…

Commissioner of Income Tax, International Taxation-1, Delhi vs. Dxc Technology Services Singapore Pte Ltd. (Earlier Known As Hp Services Singapore Pte Ltd.)

The appeals are dismissed against the

ITA - 582 / 2025HC Delhi06 Nov 2025
Section 143(3)Section 144C

…ated as royalty within the meaning Article 12(3) of the India Singapore Double Taxation Avoidance Agreement. 5.1. The Tribunal relied upon the judgment of the Supreme Court rendered in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471. Signed By:PRADEEP SHARMA Signing Date:04.12.2025 10:40:39 Signature Not Verified ITA 581/2025 & connected Page 4 of 9 6. Having regard to the findings of fact and…