JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

206, wherein section 14 of the Copy Right Act has been referred to, which explains the meaning of copyright and vide paras 20 and 21, the issue has been explained and decided in favour of assessee and it has been held that the issue has to be decided in the light of definition of ‘royalty’, as contained in DTAA read

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

206, wherein section 14 of the Copy Right Act has been referred to, which explains the meaning of copyright and vide paras 20 and 21, the issue has been explained and decided in favour of assessee and it has been held that the issue has to be decided in the light of definition of ‘royalty’, as contained in DTAA read

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SPADEWORK SOFTWARE SERVICES P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX (CPC) -TDS, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SPADEWORK SOFTWARE SERVICES P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX (CPC) -TDS, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SPADEWORK SOFTWARE SERVICES P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX (CPC) -TDS, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E

SHATABDI INSTITUTE OF ENGINEERING AND RESEARCH,AGASKHIND vs. ACIT, CPC(TDS),, GHAZIABAD

In the result, the appeals in ITA No

206 (SC) dated 08-03-2021 and 421 ITR 314. 4. There is a common grievance in all these appeals before us and at the time of hearing, the respective Counsels for the aforestated assessees submitted that the only issue for adjudication is that the Department has erred in law and on facts in levying fees u/s 234E