Software sale and ancillary support receipts remain outside royalty and technical-service fee taxation on unchanged facts.

Software-sale receipts and connected ancillary support-service receipts are described as not taxable as royalty or fees for technical services where the factual matrix remained unchanged from an earlier assessment year. The analysis notes that the earlier-year position had already resolved the same issue consistently with the principle in Engineering Analysis Centre for Excellence Private Limited, leaving no basis for a different treatment in the relevant year. The stated conclusion is that these receipts are not assessable as royalty or fees for technical services.

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Issues: Whether consideration received from sale of software and ancillary support services is taxable as royalty or fees for technical services.

Analysis: The assessee's case for an earlier assessment year had already determined the same question on an unchanged factual matrix, consistently with the principle in Engineering Analysis Centre for Excellence Private Limited. No basis existed for a different view for the relevant year.

Conclusion: The software-sale receipts and connected ancillary support-service receipts are not assessable as royalty or fees for technical services, in favour of the assessee.

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