BMC SOFTWARE ASIA PACIFIC PTE LTD,SINGAPORE vs. ACIT (INTERNATIONAL TAX) CIRCLE-1, PUNE
In the result, the appeal is allowed
ITA 2048/PUN/2019[2010-11]Status: DisposedITAT Pune03 Sept 2021AY 2010-11
Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryनिर्धारण वषा / Assessment Year: 2010-11 Bmc Software Asia Pacific Pte Vs. Acit (International Tax), Ltd., Circle-1, Pune 600, North Bridge Road, 20-01/10 Park View Square, Singapore – 188778 Pan : Aaecb0642A Appellant Respondent
Section 143(3)Section 148
u/s 148 of the Act. On being show caused as to why income from sale of software was not offered for taxation, the assessee submitted that it was not the owner of the software licenses rather it was only permitted to distribute such software licenses in the Asia Pacific region. Relying on the judgment of Hon‟ble Karnataka High Court
