9911796707
TMI Blog2014 (1) TMI 1877X X X X Extracts X X X X X X X X Extracts X X X X ..... disallowance u/s 40(a)(i) in respect of the amounts paid by the assessee to M/s Abaqus In the case of, without deduction of tax at source - CIT-A deleted addition treating the same as not taxable in India under Section 9(1)(vi) - assessing authority has treated the payments in the nature of royalty as against payments towards purchase consideration, as argued by the assessee - HELD THAT:- This is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt And Shri Vikas Awasthy, Judicial Member Assessee by : Shri Sriram Seshadri, CA Revenue by : Shri T.N. Betgeri, IRS, JCIT ORDER Dr.O.K.Narayanan, This is a bunch of five appeals. Four appeals are filed by the assessee for the assessment years 2003-04, 2004-05, 2005-06 and 2006-07. The fifth appeal is filed by the Revenue for the assessment year 2009-10. 2. The issue raised in all the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng authority has treated the payments in the nature of royalty as against payments towards purchase consideration, as argued by the assessee. 6. This issue has already been decided by the ITAT, Chennai B-Bench in the case of Dassault Systems Simulia P. Ltd. (formerly known as Abacus Engineering Pvt. Ltd.) through their order dated 16th September, 2011 (2011-TII-143-ITAT-MAD-INTL). After consider ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
