2024 (12) TMI 863

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..... mounting to royalty u/s 9(1)(vi) ? - HELD THAT:- The controversy involved in the present appeal is squarely covered by a judgment of Engineering Analysis Centre of Excellence Private Limited [ 2021 (3) TMI 138 - SUPREME COURT] and in view thereof, the appeal of the Revenue deserves to be dismissed. - THE HON BLE JUSTICE SURYA PRAKASH KESARWANI AND THE HON BLE JUSTICE AJAY KUMAR GUPTA Mr. Prithu .....

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..... he learned counsel for the parties jointly state that the controversy involved in the present appeal is squarely covered by a judgment of Hon ble Supreme Court in Engineering Analysis Centre of Excellence Private Limited v. Commissioner of Income Tax Another (2022) 3 SCC 321 (paragraphs 84-90) and in view thereof, the appeal of the Revenue deserves to be dismissed. 4. In view of the aforesaid, the .....

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