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TMI Blog2015 (10) TMI 2513X X X X Extracts X X X X X X X X Extracts X X X X ..... le 12 of DTAA between India and US - Held that:- Even though there is amendment to the Finance Act, 2012, there is no change in the DTAA between India and USA and the same was not refuted by the DR. Therefore, in light of assessee’s own case for the A.Y 2008-09 [2014 (4) TMI 369 - ITAT DELHI ]appeals are covered in assessee’s favour wherein held what has been transferred is not copyright or the ri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vered by assessee's own case for the A.Y 2008-09 in favour of the assessee being ITA No. 5209/Del/2011 (order dated 14.02.2014 passed by the ITAT, Delhi Bench). The same is taken on record and perused. The Hon'ble Delhi High Court vide EITA 477/2014 (order dated 01.09.2014) has also confirmed the same. 2. However, the DR submitted that there is retrospective amendment and Revenue has filed appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s are covered in assessee's favour. The submissions made by the DR relating to amendment does not sustain in view of decision in assessee's own case for previous assessment year. As relates to Hon'ble Karnataka High Court's decision, the same will not be applicable as the jurisdictional High Court in assessee's own case for the previous year has held the decision in favour of the assessee. 4. In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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