Writ petitions challenging the Rulings of AAR is filed before the High Courrt. Court held that the payment received by UK Company for providing access to computer software to Indian Company did not amount to royalty liable to be taxed in India under section 9(1)(vi) as well as article 13 of India-UK DTAA.Petitions are allowed.
EY Global Services Ltd. v. ACIT (2022) 441 ITR 54 / 285 Taxman 10 / 209 DTR 1 / 324 CTR 149 (Delhi)(HC)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Providing access to computer software to Indian comoany-Not royalty-Not liable to be taxed in India-DTAA-India-UK. [Art. 13, Copy right Act, 1957, S. 14, Art. 226]