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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Prashant Maharishi, VP, Soundararajan K., J
Arista Networks Limited – Appellant
Versus
The Deputy Commissioner of Income Tax (International Taxation) – Respondent
| Table of Content |
|---|
| 1. assessment order details and grounds of appeal (Para 1 , 2) |
| 2. general grounds dismissed; focus on specific income streams (Para 3 , 4 , 5) |
| 3. nature of income streams and taxability (Para 6 , 10 , 11) |
| 4. supreme court ruling on copyright and tax implications (Para 18 , 19 , 20) |
| 5. assessment of income streams not qualifying as royalty (Para 22 , 23 , 24) |
| 6. final ruling on appeal and taxability (Para 27 , 28) |
O R D E R
1. This appeal is filed by Arista Networks Limited (the assessee/appellant) , resident of Ireland, for the assessment year 2021-22 against the assessment order passed by the DCIT, International Taxation, Circle 1(1), Bangalore u/s. 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 [the Act] dated 29.10.2023 wherein the total income of the assessee is assessed at Rs.39,48,95,582 against the revised return filed by the assessee on 27.6.2022 at Rs.3,65,76,506.
“The grounds mentioned herein are without prejudice to one another:
2. That on the facts of the case and in law, the AO erred in making an addition of Rs. 35,83,19,076/- to the total income of the Appellant for assessment year 2021-22.
4. That the AO and the DRP erred on facts and in law in not apprecia
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