Royalties/Fees for technical services – Subscription fee : SLP dismissed against order of High Court that where assessee-company had made foreign remittance to Red Hat, Singapore without deducting tax at source on ground that payment for purchase of subscription was not taxable as per article 7 but Assessing Officer held that impugned subscription fees was liable to be taxed as ‘royalty’ and assessee was treated as assessee-in-default, since there was no liability of Red Hat, Singapore to pay tax in India and no assessment had been made in respect of tax liability of said company, assessee could not be saddled with liability under section 201 – Commissioner of Income-tax (IT) v. Red Hat India (P.) Ltd. – [2024] 164 taxmann.com 605 (SC)
Skip to content
Skip to footer