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Case Lawsuit Title
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Case / Trial ID Number
Jurisdiction Code
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us
in
upc
eu
Category
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Patent
Trademark
Copyright
Design
Filing Date
Decision Verdict Date
Court / Tribunal
Bench / Panel Judges
Petitioner / Claimant (Plaintiff)
Samsung Electronics Company Limited
Respondent / Defendant
Assessee
Dispute Summary
The appeal challenged the assessment that payments made by Samsung Electronics to DSP Asia Pte Ltd. for purchasing 'shrink-wrapped software' constituted royalty, thereby requiring TDS deduction under Section 195 of the Income Tax Act. The Tribunal upheld the revenue's view, citing a previous judgment in the assessee's own case where the High Court had held that such payments were indeed royalty.
Outcome / Ruling
defendant_favorable
Verdict Document PDF URL
Full text judgment
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