Software licensing and cloud subscription receipts raised no substantial question of law after Engineering Analysis ruling.

Income from licensing or sale of software and subscription receipts for cloud services were examined against the Supreme Court's ruling in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, which was treated as covering the revenue's proposed questions. On that basis, the court held that the issues raised did not survive as substantial questions of law. The appeal was closed.

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Issues: Whether income from licensing or sale of software and subscription receipts for cloud services constituted royalty so as to give rise to a substantial question of law in the revenue's appeal.

Analysis: The appeal was examined in the light of the Supreme Court's ruling in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, which covered the questions proposed by the revenue. On that basis, the court found that the issues raised did not survive for consideration as substantial questions of law.

Outcome: The appeal was closed.

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