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of <h1>Software Sale Not Royalty: HC Upholds ITAT Ruling Under Indo-Singapore Tax Treaty, Dismisses Appeal.</h1> <h3>The Commissioner Of Income Tax –International Taxation-1 Versus DXC Technology Services Singapore Pte. Ltd. (Formerely Known As Hp Services (Singapore) Pvt. Ltd.</h3> The Commissioner Of Income Tax –International Taxation-1 Versus DXC Technology Services Singapore Pte. Ltd. (Formerely Known As Hp Services (Singapore) ... Issues involved:The appeal concerns Assessment Year (AY) 2009-10. The appellant/revenue seeks to challenge the order passed by the Income Tax Appellate Tribunal regarding the consideration received by the Assessee from various entities on account of sale/supply of software, questioning whether it qualifies as royalty under the Indo-Singapore Double Taxation Avoidance Agreement.Summary:The respondent/assessee underwent scrutiny-assessment, where the consideration received for the off-the-shelf sale of software was brought to tax, resulting in an addition of Rs. 1,14,09,24,658 by the Assessing Officer (AO) who considered it as royalty. However, the Tribunal ruled in favor of the respondent/assessee, stating that the amount cannot be treated as royalty as the copyright of the software was not transferred by the assessee. The Tribunal's decision was based on the Supreme Court judgment in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. v CIT 432 ITR 471, which was deemed appropriate. Therefore, the High Court found no substantial question of law to interfere with the Tribunal's order and closed the appeal, rendering the pending application infructuous.
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