Dismissing the appeal of the revenue the Court held that Amount paid to Associated Enterprise towards embedded software is not royalty. Followed CIT(IT) v ZTE Corporation (2017) 392 ITR 80 (Delhi)(HC). Held no substantial question of law.
CIT v. Nortal Network India International Inc (2019) 267 Taxman 523 / 111 taxmann.com 224 (Delhi)(HC) Editorial: SLP is granted to the revenue is allowed CIT v Nortal Network India International Inc ( 2019)267 Taxman 522 (SC).
S. 9(1)(vi) : Income deemed to accrue or arise in India–Royalty– Amount paid to Associated Enterprise towards embedded software– Not royalty-No substantial question of law.[S. 260A]