ACIT, CIRCLE-2(1)(1),AGRA, AGRA vs. EMCO EXPORTS, AGRA
In the result, revenue’s appeal stands dismissed
ITA 415/AGR/2025[2020-21]Status: DisposedITAT Agra15 Jan 2026AY 2020-21
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21
Section 195Section 250Section 40Section 9
209, relied on by the department, dealt on whether tax is to be deducted at source, under section 195 of the Act, in respect of payment made to non- resident, on import of software. The judgment of the Karnataka
High Court is largely based on the judgment of Supreme Court in the case of Transmission Corporation