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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Sandeep Gosain, Judicial Member, Prabhash Shankar, Accountant Member
DCIT- Circle 1(3)(1) – Appellant
Versus
Diebold India Private Limited – Respondent
| Table of Content |
|---|
| 1. introduces appeals and procedural consolidation. (Para 1 , 2) |
| 2. revenue challenges tds deletion on software payments. (Para 3 , 4) |
| 3. eula payments for software not royalty under dtaa/section 195. (Para 5 , 6 , 7 , 8 , 9) |
ORDER
Per Sandeep Gosain, JM:
The present appeals have been filed by the Revenue and cross objections by the assessee challenging the different impugned orders dt. 03.06.2025, 04.06.2025, 04.06.2025 & 04.06.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment years 2010-11, 2011-12, 2012-13 & 2013-14.
2. Since all the issues involved in these appeals and cross objections is common and identical and belongs to one assessee therefore, they have been clubbed, heard together and consolidated order is being passed. Firstly, we shall take ITA No. 5505/Mum/2025, A.Y 2010-11 as lead case and facts narrated therein.
ITA No. 5505/Mum/2025, A.Y 2010-11
3. The revenue has raised the following grounds of appeal:
1 Whether on the facts and circumstances of the case and in law, Ld. CIT(A) was justified in deleting the disallowance of Rs. 18,42,93,456/-u/s 40(a)(i) of the Income
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