Subscription Payment received by End user to a non-resident Computer supplier is not royalties: Delhi HC Dismisses Revenue’s Appeal [Read Order]
Subscription payments could not be considered as royalty under the provisions of Article 12(3) of the India Ireland Double Taxation Avoidance Agreement [DTAA].
The Delhi High Court has dismissed the revenue’s appeal and upheld the ruling that the subscription payment received by an end user from a non-resident computer supplier is not royalties. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [the Act] impugning an order dated 05.08.2024 passed by…
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