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TMI Blog2023 (2) TMI 1177X X X X Extracts X X X X X X X X Extracts X X X X ..... ts nor subscription fee earned for providing cloud services, could be construed as royalty - HELD THAT:- As revenue, says that the proposed questions are covered by the judgment of Engineering Analysis Centre of Excellence (P.) Ltd. [ 2021 (3) TMI 138 - SUPREME COURT] . We are also informed that a review petition has been filed which is pending consideration. Accordingly, the appeal is closed a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by MOL Corporation is not taxable in India as Royalty under Section 9(1)(vi) of the Income Tax Act, 1961 read with Article 12 of the Indo-USA DTAA? B. Whether on the facts and circumstances of the case and in law, the Ld. ITAT erred in holding that licensing of computer is copyrighted article and not copyright and accordingly the sale of software is in nature of business income and not taxab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e construed as royalty. 6. Mr Sanjay Kumar, senior standing counsel, who appears on behalf of the appellant/revenue, says that the proposed questions are covered by the judgment of the Supreme Court rendered in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT 432 ITR 471 (SC). 6.1. We are also informed by Mr Kumar that a review petition has been filed which is pending consideration ..... X X X X Extracts X X X X X X X X Extracts X X X X
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