2022 (10) TMI 665

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..... foreign software Supplier - Double Tax Avoidance Agreement - HELD THAT:- The impugned judgment(s) passed by the High Court of Karnataka at Bangalore had relied on the earlier judgment of the High Court in the case of Samsung Electronics Co. Ltd. [ 2011 (10) TMI 195 - KARNATAKA HIGH COURT] which judgment has been set aside and overruled by this Court in the decision reported as Engineering Analysis .....

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..... of Income Tax International Taxation Another v. Engineering Analysis Centre of Excellence Private Limited Etc., is pending. In case any order is passed, it will be open to the parties to rely upon the said order. The appeals are disposed of in the aforesaid terms.
Hon'ble Mr. Justice Sanjiv Khanna And Hon'ble Mr. Justice J.K. Maheshwari For the Parties : Mr. Balbir Singh, ASG, Mr. Asho .....

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..... ted v. Commissioner of Income Tax & Another [(2022) 3 SCC 321]. Before us, learned counsel for both parties have rightly stated that the facts, as found by the Income Tax Appellate Tribunal and the authorities have not been analyzed by the High Court. In view of the aforesaid position, we set aside the impugned judgment with an order of remand to the High Court to re-examine the issue and the qu .....

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