Software licensing and cloud subscription receipts treated as non-royalty; no substantial question of law arose in appeal.

Software licensing income, sale of software products and cloud service subscription receipts were treated as non-royalty by the Tribunal. On appeal, the Revenue relied on the Supreme Court's ruling in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, and the court noted that a review petition on that issue was pending. No substantial question of law arose for interference, and the appeal was closed.

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Issues: Whether the appeal raised any substantial question of law warranting interference in respect of taxability of software licensing income and cloud service subscription receipts.

Analysis: The Tribunal had held that income from licensing and sale of software products as well as subscription receipts for cloud services did not constitute royalty. In appeal, the Revenue relied on the decision of the Supreme Court in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, and it was also noted that a review petition on that subject was pending.

Conclusion: No substantial question of law arose for consideration, and the appeal was closed.

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