2024 (3) TMI 670

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..... assessee - scope of Indo-USA DTAA - HC said [ 2024 (3) TMI 581 - DELHI HIGH COURT] Tribunal has ruled that neither income earned from licensing of software products nor subscription fee earned for providing cloud services, could be construed as royalty and as revenue says that the proposed questions are covered by the judgment rendered in Engineering Analysis Centre of Excellence (P.) Ltd. [ 2021 .....

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..... R Mr. Viyushti Rawat, Adv. ORDER UPON hearing the counsel the Court made the following. Delay condoned. Following the earlier order passed by this Court in the Case of Commissioner of Income Tax V/s. M/s. Gracemac Corporation dated 03.07.2023, which had followed the earlier judgment of this Court in the case of Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income Ta .....

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