2023 (4) TMI 1234 - SCH - Income Tax

TDS u/s 195 - Royalty - taxability of software receipts - Whether constitutes as taxable income deemed to accrue in India u/s 9(1)(vi)? - income deemed to accrue or arise in India - HELD THAT - In view of the order passed in M/S MOL CORPORATION 2023 (5) TMI 1065 - SC ORDER dismissing the similar Special Leave Petition wherein issue raised by the Revenue is covered against them vide judgment in the case of Engineering Analysis Centre of Excellence Private Limited 2021 (3) TMI 138 - SUPREME COURT , the present Special Leave Petition also stands dismissed. Pending application(s) shall stand disposed of.

Summary

The Supreme Court of India, with Justices M.R. Shah and C.T. Ravikumar, dismissed a Special Leave Petition due to a similar previous dismissal in SLP (C) No.5857/2023. Delay was condoned, and pending applications were disposed of. The Respondent did not appear.