Software licensing and cloud subscription receipts not treated as royalty; appeal closed for no substantial question of law.

Income from licensing and sale of software products, and subscription receipts from cloud services, was treated as not taxable as royalty under the Income-tax Act and the relevant DTAA provisions. The Tribunal's view followed the Supreme Court ruling in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, and the High Court found no contrary substantial question of law for consideration. The revenue's appeal was therefore closed, leaving the Tribunal's conclusion undisturbed.

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Issues: Whether income from licensing and sale of software products, and subscription receipts from cloud services, was taxable as royalty under the Income-tax Act and the relevant DTAA provisions.

Analysis: The Tribunal had held that neither the income from licensing or sale of software products nor the subscription fee for cloud services constituted royalty. The appeal was stated to be covered by the Supreme Court decision in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, and no contrary substantial question of law was shown to arise for consideration.

Conclusion: The Tribunal's view was left undisturbed and the revenue's appeal was closed on the ground that no substantial question of law arose.

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