1. Arbitral award received by Fujitsu Ltd from the state-owned telecom operator (MTNL) was held by the Delhi Bench of Income Tax Appellate Tribunal (ITAT) to be NOT taxable in India [ITA No. 2607/Del/2022]. The said award has been held to be ‘business income’ and not income from ‘other sources’. Since the taxpayer did not have a Permanent Establishment (PE) in India, the same was held to be not taxable in India as per Art. 7 of the India Japan Double Taxation Avoidance Agreem

01 March 2021​ Tomorrow Supreme Court of India will pronounce its judgment on the decade old Software Royalty issue. Three-Judges-Bench headed by Justice Rohinton Fali Nariman had reserved their judgment on 18th Feb 2021 after hearing the batch of 87 appeals for five days from 9th to 18th Feb 2021. It may be recalled that Karnataka High Court (in CIT v. Samsung Electronics Co. Ltd.) had held that the payment made towards purchase of shrink wrapped software was in the nature o