Delhi H.C : The assessee is a company incorporated in USA and into the business of supplying and replication of software. The assessment order u/s 143(3) of the Act was passed for the relevant assessment year on March 28, 2005 wherein it was established that the assessee has PE in India under Article 5 of the DTAA as well as „business connection? u/s 9(1)(i) of the Act. The receipts of the assessee i.e. „receipts from software? have been treated as „royalty?
High Court Of Delhi Oracle Systems Corporation vs. Assistant Director Of Income Tax (International Taxation) Section 44D, 143(3), 147, 148 […]
