S.V.MEHROTRA, JOGINDER SINGH
ONGC Videsh Ltd. – Appellant
Versus
Income-tax Officer, International Taxation, TDS, Ward 2(1), New Delhi – Respondent
Joginder Singh, Judicial Member - This bunch of five appeals is by the assessee for assessment years 2007-08 to 2009-10 on the ground that on the facts and in the circumstances of the case, ld. first appellate authority erred in law and in fact in upholding the assessment order under section 195/197 of the Act ignoring the agreement, definition of royalty, and further erred in holding that in the agreement entered into between the assessee and Wood Mackenzie, the assessee got a licence to use/access to scientific work without appreciating the nature of information received by the assessee on payment of access fee.
2. During hearing of these appeals, we have heard Shri Pawan Kumar along with Shri Ravi Sharma, ld. counsels for the assessee and Shri Jasdeep Singh, ld. Senior DR. The assessee has also filed synopsis. The crux of argument is that the subscription fees paid by the assessee to Wood Mackenzie (in short hereinafter, WM) is not in the nature of royalty for information conforming industrial, commercial or scientific experience because WM is not importing any information, knowledge or skill from its experience acquired over a period of time. It was submitted that the indus
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