2019 (10) TMI 1508

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..... preet Singh Ajmani and Mr. Rohan Khare, Advocates. ORDER C.M. No. 45711/2019 in ITA 911/2019 (exemption) C.M. No. 40377/2019 in ITA 817/2019 (exemption) 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. C.M. No. 45712/2019 (delay) in ITA 911/2019 3. By this application the applicant seeks condonation of delay of 61 days in re-filing the application .....

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..... 2019, ITA 769/2019 & ITA 771/2019 3. At the outset, Mr. Ruchir Bhatia learned counsel for the Appellant very fairly states that the issues/questions framed in the present appeals are covered by the decision of this Court in Commissioner of Income Tax, International Taxation v. ZTE Corporation (2017) 392 ITR 80 (Delhi). The questions of law framed in the said appeal were as follows: "(i) Are th .....

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..... nomenclature (of license or some other fee) is indeterminate of the true nature. Nor is the circumstance that updates of the software are routinely given to the assessee's customers. These facts do not detract from the nature of the transaction, which was supply of software, in the nature of articles or goods. This court is also not persuaded with the submission that the payments, if not royalty, .....

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