2023 (2) TMI 1303

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... l has ruled that neither income earned from licensing/sale of software products nor subscription fee earned for providing cloud services, could be construed as royalty - 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] HELD THAT:- We are as informed by Appellant that a review petition ha .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... . According to the appellant/revenue, there is delay of 100 days. 3. Counsel for the respondent/assessee, says that he has no objection if the delay in re-filing the appeal is condoned. 4. Accordingly, the delay in re-filling the appeal is condoned. 5. The application is disposed of, in the aforesaid terms. ITA 100/2023 6. This appeal concerns Assessment Year (AY) 2012-13. 7. This appeal assails t .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... he Ld. ITAT erred in holding that the subscription received towards Cloud Services is not taxable as Royalty income under the provisions of Income Tax Act, 1961? 9. As would be evident the first two questions of law [i.e., A and B] relate to income earned from licensing/sale of software while the third question [i.e., C] relates to subscription receipts against cloud services offered by the respon .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X