2024 (3) TMI 670 - SCH - Income Tax

Accrual of income in India - Royalty receipts - income earned from licensing/sale of software and subscription received against cloud services offered by assessee - scope of Indo-USA DTAA - HC said 2024 (3) TMI 581 - DELHI HIGH COURT Tribunal has ruled that neither income earned from licensing of software products nor subscription fee earned for providing cloud services, could be construed as royalty and as revenue says that the proposed questions are covered by the judgment rendered in Engineering Analysis Centre of Excellence (P.) Ltd. 2021 (3) TMI 138 - SUPREME COURT , no substantial question of law arises for our consideration HELD THAT - Following the earlier order passed by this Court in the Case of Commissioner of Income Tax V/s. M/s. Gracemac Corporation 2023 (8) TMI 98 - SC ORDER which had followed the earlier judgment of this Court in the case of Engineering Analysis Centre of Excellence Private Limited 2021 (3) TMI 138 - SUPREME COURT this Special Leave Petition is also dismissed.

Summary

The Supreme Court in the case mentioned dismissed the Special Leave Petition following earlier judgments. The delay was condoned, and pending applications were disposed of.