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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Beena Pillai, J, Chandra Poojari, ACJ
YODLEE INC BANGALORE – Appellant
Versus
THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(2) BANGALORE – Respondent
| Table of Content |
|---|
| 1. introduction of the case and appeal grounds (Para 1 , 2) |
| 2. background facts of the assessee's operations (Para 3) |
| 3. arguments against the taxability of income as royalty (Para 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 18) |
| 4. court analysis and application of legal provisions (Para 13 , 14 , 15 , 16 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 34 , 35 , 36 , 37 , 38) |
ORDER
PER BEENA PILLAI, JUDICIAL MEMBER
Present appeals arises out of the final assessment order dated 07.07.2022 for A.Y. 2019-20 and order dated 10.07.2023 for A.Y. 2020-21 passed by the Ld.DCIT, Intl. Taxation, Circle – 2(2), Bangalore.
2. Grounds of appeal raised by assessee for A.Y. 2019-20 are as under:
Based on the facts and circumstances of the case and in law, Yodlee Inc. (hereinafter referred to as "the Assessee Company" or ''the Appellant") respectfully craves, leave to prefer an appeal under Section 253 (1)(d) of the Income-tax Act, 1961 ("the Act") against the order dated 07 July 2022 issued under Section 143 (3) read with Section 144C (13) of the Act, by the Deputy Commissioner of Income-tax, International Taxation. Circle-2(2), Bengaluru (the "Learned AO") in pursuanc
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