CRM software licensing under India Singapore DTAA ruled not to constitute royalty; cross border tax appeal dismissed.

Consideration for licensing of Customer Relationship Management (CRM) software was held not to qualify as royalty under the India Singapore DTAA; the ITAT's conclusion that such receipts are outside Article 12(3)'s royalty definition was affirmed, with the special leave petition dismissed by the Supreme Court, leaving the tax treatment in favour of the taxpayer (a Singapore resident) intact. The decision rests on treaty interpretation of licence receipts for software and confirms that the licensing structure at issue does not convert those receipts into taxable royalty income in India under the DTAA.

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The Supreme Court, with Hon'ble Justices Pamidighantam Sri Narasimha and Atul S. Chandurkar presiding, after hearing counsel, issued the following order: "Delay condoned," and dismissed the Special Leave Petition. All pending applications, if any, were disposed of.

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