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Delhi High Court: Software Receipts Not Taxable on PE Basis Already Rejected by ITAT - (24 Dec 2025)

DIRECT TAXATION

Delhi High Court ruled that software receipts cannot attract TDS based on a presumed permanent establishment when the ITAT has already rejected such an assumption, and accordingly set aside the withholding certificate issued under Section 197 of the Income Tax Act.

Tags : SOFTWARE RECEIPTS   TAXABLE   INCOME TAX ACT  

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