Held dismissing the appeal, the Court held that the Tribunal was right in concluding that the consideration received by the assessee did not constitute royalty and was not assessable in India.(AY.2011-12)
CIT (IT) v. Cognyte Technologies Israel Ltd. [2023] 155 taxmann.com 292 / (2025)472 ITR 476 (Delhi)(HC)
S. 9(1)(vi) : Income deemed to accrue or arise in India- Royalty- Transfer of off-the-shelf- Software-Not assessable in India as royalty-DTAA-India- Israel. [S. 260A, Art. 12 (3)]
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