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TMI Blog2016 (3) TMI 1473X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. Assessee-company is engaged in the business of market research information and analysis. Details of dates of filing of returns of income, returned income, dates of assessment and the assessed income can be summarised as under :- A.Y. ROI filed on Returned Income (Rs.) Assessment dt. Assessed Income (Rs.) Dt. of orders of CIT(A) 2007-08 24.10.2007 Nil 28/01/2011 15, 06, 52, 986/- 30.09.2013 2008-09 17.09.2008 Nil 30.01.2012 12, 94, 91, 336/- 30.09.2013 2009-10 14.09.2009 Nil 20.05.2013 13, 90, 00, 630/- 27.02.2014 2.1. During the course of hearing before us Representatives of both the sides agreed that similar issue hava been dealt by the Tribunal, while deciding the appeal for the A.Y.s 2004- 05 to 2006-07 (ITA N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es services regarding group policies; e. Legal services; f. Insurance services; g. development, control and maintenance of management information systems; h. administrative support to group companies, including analysis of management information; i. development short and long term IT policies and strategies; j. management and co-ordination of IT policies between group companies; k. tax services; l. financial risk management services, to the extent these services do not comprise Financing Services. m. support in the area of international staffing, career development and international job rotation and n. market research, target research and competitor research " For providing the services enumerated above, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x Act, Copyright Act and certain decisions rendered in some other context. In fact, the AO took the view that the entire consideration is taxable as "Royalty" in AY 2004- 05, but changed his view in the subsequent two years. In respect of the assessment year 2004- 05 also, the assessing officer has furnished a remand report before the Ld CIT(A), wherein he had suggested that the impugned receipt is required to be treated as both "Royalty" and "Fees for included services". 8. The expressions "Royalty" and "Fees for included services" have been given distinct meaning in the Indo US treaty. We have already noticed that the tax authorities were not able to come to a conclusion as to whether the consideration received by the assessee company ..... X X X X Extracts X X X X X X X X Extracts X X X X
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