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![Sale of Software is not “Royalty” under Article 12(3) of Indo-US Treaty: ITAT [Read Order] Sale of Software is not “Royalty” under Article 12(3) of Indo-US Treaty: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Sale-of-Software-Royalty-Indo-US-Treaty-ITAT-TAXSCAN.jpg)
Sale of Software is not “Royalty” under Article 12(3) of Indo-US Treaty: ITAT [Read Order]
The Delhi Income Tax Appellate Tribunal has recently held that sale of software is not royalty under article 12(3) of Indo –US treaty. Assessee...



![Late Fee u/s 234E Not Leviable for Belated Filing of TDS statements Filed Prior to 01.06.2015: ITAT [Read Order] Late Fee u/s 234E Not Leviable for Belated Filing of TDS statements Filed Prior to 01.06.2015: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Late-Fee-Belated-Filing-TDS-statements-TDS-ITAT-Taxscan.jpg)
![Dumb Documents found from Third Party does not contain Assessee’s Name, No Addition u/s 153C: ITAT [Read Order] Dumb Documents found from Third Party does not contain Assessee’s Name, No Addition u/s 153C: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Dumb-Documents-Documents-Third-Party-Assessees-Name-Assessee-Addition-ITAT-Taxscan.jpg)
![Interim Relief to AWS: ITAT Stays Recovery of Rs. 549 Crores towards Addition of Income from Cloud Computing Services [Read Order] Interim Relief to AWS: ITAT Stays Recovery of Rs. 549 Crores towards Addition of Income from Cloud Computing Services [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/AWS-ITAT-Addition-Income-Computing-Services-TAXSCAN.jpg)
![“State cannot Clutch the Undue Benefit of Mistake Committed by Tax Payer”: ITAT [Read Order] “State cannot Clutch the Undue Benefit of Mistake Committed by Tax Payer”: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Undue-Benefit-Tax-Payer-Tax-ITAT-Taxscan.jpg)
![Notice Issued u/s 271(1)(c) of Income Tax Act is Omnibus: ITAT deletes Penalty Proceedings [Read Order] Notice Issued u/s 271(1)(c) of Income Tax Act is Omnibus: ITAT deletes Penalty Proceedings [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Notice-Income-Tax-Act-Income-Tax-Tax-ITAT-Penalty-Taxscan.jpg)
![Estimation of Cash based on Surmises and Conjectures cannot be made in Rectification Order u/s 154: ITAT [Read Order] Estimation of Cash based on Surmises and Conjectures cannot be made in Rectification Order u/s 154: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Estimation-of-Cash-Rectification-Order-ITAT-cash-taxscan.jpeg)
![Remuneration to Guest Faculties Not “Salary”, No TDS: ITAT deletes Order Against Educational Institution [Read Order] Remuneration to Guest Faculties Not “Salary”, No TDS: ITAT deletes Order Against Educational Institution [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Educational-Institution-Salary-TDS-ITAT-Income-Tax-Tax-Taxscan.jpg)
![Death of Assessee during Income Tax Assessment Proceedings: ITAT directs Re-Adjudication [Read Order] Death of Assessee during Income Tax Assessment Proceedings: ITAT directs Re-Adjudication [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Income-Tax-Assessment-Income-Tax-Assessment-ITAT-Re-Adjudication-Taxscan.jpg)
![Sale and Purchase of Mutual Funds by Maruti Suzuki can be treated as Business Income If Activities of Investment are towards Business Profit: ITAT [Read Order] Sale and Purchase of Mutual Funds by Maruti Suzuki can be treated as Business Income If Activities of Investment are towards Business Profit: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Sale-Purchase-Mutual-Funds-Maruti-Suzuki-Business-Income-Investment-Business-Profit-ITAT-Taxscan.jpg)
![Payment for Business Support Services from Foreign Company not “Fee for Technical Services”: ITAT [Read Order] Payment for Business Support Services from Foreign Company not “Fee for Technical Services”: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Payment-Business-Services-Foreign-Company-Fee-Technical-Services-ITAT-TAXSCAN.jpg)
![Disallowance cannot be Made on Ad-Hoc Basis Without Any Specific Allegation Merely on the basis of General Remarks and Observations: ITAT [Read Order] Disallowance cannot be Made on Ad-Hoc Basis Without Any Specific Allegation Merely on the basis of General Remarks and Observations: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/03/Disallowance-ITAT-taxscan.jpg)