2019 (10) TMI 1541 - HC - Income Tax

Income deemed to accrue or arise in India - ITAT held as not chargeable to tax under section 9(1)(vi) read with Article 12(3) of the DTAA between India and USA as royalty - HELD THAT - The present appeal is directed against the order passed by the Income Tax Appellate Tribunal Delhi Bench (ITAT) G‟, New Delhi in 2019 (4) TMI 1426 - ITAT DELHI in respect of the assessment year 2012-13. The Tribunal has placed reliance on the decisions of this Court in M/s Asia Satellite Telecommunications Co. Ltd. 2011 (1) TMI 47 - DELHI HIGH COURT and Director of International Taxation Vs. New Skies Satellite BV, 2016 (2) TMI 415 - DELHI HIGH COURT . Since the issues raised by the Revenue are squarely covered by the aforesaid decisions of this Court, in our view, no question of law arises for our consideration.

Summary

The Delhi High Court dismissed the appeal against the ITAT order for the assessment year 2012-13, citing previous decisions of the court. The appeal was found to have no question of law for consideration.