M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PVT. LTD.,),BANGALORE vs. PR. CIT - 3, BANGALORE
In the result, the assessee’s appeal for assessment year 2010-11 is allowed
ITA 1101/BANG/2016[2010-11]Status: DisposedITAT Bangalore05 Dec 2018AY 2010-11
Bench: Shri Jason P Boaz & Shri Laliet Kumarassessment Year : 2010-11 M/S. Harman Connected Services Vs. Principal Commissioner Of Corporation India Private Limited, Income-Tax, [Formerly Known As Symphony Bangalore - 3. Teleca Corporation India Private Limited) No.3 & 3A, Eoiz Industrial Area, Survey No. 85 & 86, Sadarmangla Village, Krishnarajapuram Hobli, Bangalore – 560 066. Pan : Aabcg 5658 E Appellant Respondent Assessee By : Shri. K. R. Vasudevan, Advocate : Revenue By Shri. C. H. Sundar Rao, Cit-I Date Of Hearing : 04.10.2018 Date Of Pronouncement : .12.2018 O R D E R
For Appellant: Shri. K. R. Vasudevan, Advocate
Section 115Section 115JSection 143(3)Section 195Section 263Section 40
TDS
5.7.1 According to the learned AR, the CIT had erroneously held that the payments made for purchase of software is in the nature of royalty and hence tax is liable to be deducted at source thereon. It was also submitted that the assessee had filed an application before the Authority for Advance Ruling (AAR) on the issue of applicability