Home › Income-Tax Act › CIT v. MOL Corporation (2023)454 ITR 32/ 293 Taxman 74 (SC) Editorial : Refer, CIT (IT) v. Mol Corporation (2023)454 ITR 28 / 150 taxmann.com 117 (Delhi)(HC)

CIT v. MOL Corporation (2023)454 ITR 32/ 293 Taxman 74 (SC) Editorial : Refer, CIT (IT) v. Mol Corporation (2023)454 ITR 28 / 150 taxmann.com 117 (Delhi)(HC)

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Non-Resident-Use of copyright in the computer software-Software receipts-Not taxable in India-DTAA-India-USA.[S. 9(1)(vi), 195]

SLP dismissed against High Court order that payments received by assessee, US company, for grant of licence for use of software and further grant of rights for distribution of software products were not taxable as ‘royalty’ under provisions of Act and also under India-US DTAA, with Liberty To Revive If Review Petition In Engineering Analysis Centre Of Excellence Pvt. Ltd. v. CIT  [2021] 432 ITR 471 (SC ).