Dismissing the SLP of the Revenue the Court held that if the review petition in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT (2021)432 ITR 471 (SC) was allowed on the issue raised in the special leave petition, it would be open to the Department to get the special leave petitions revived.(AY. 1999-2000 to 2001-02)
DIT(IT) v. Microsoft Regional Sales PTE. Ltd. (2023)454 ITR 19/ 294 Taxman 519 (SC) Editorial: DIT(IT) v. Microsoft Regional Sales PTE. Ltd. (2023)454 ITR 15 (Delhi) (HC), affirmed.
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Receipts from sale of software licences to Indian customers-Software receipts is not taxable as royalty-SLP of Revenue is dismissed. [Art. 136]