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Receipts from sale of software products and ancillary support services to Indian distributors, resellers and customers were held not taxable in India as royalty or fees for technical services under the India-USA DTAA. The Tribunal noted that earlier Karnataka High Court rulings relied on by the Assessing Officer had been reversed by the Supreme Court in Engineering Analysis Centre for Excellence Pvt. Ltd., and that position had attained finality after dismissal of the review petition. Applying that binding law, it upheld the Commissioner (Appeals)' relief and dismissed the revenue's appeal.
Receipts from sale of software products and ancillary support services to Indian distributors, resellers and customers were held not taxable in India as royalty or fees for technical services under the India-USA DTAA. The Tribunal noted that earlier Karnataka High Court rulings relied on by the Assessing Officer had been reversed by the Supreme Court in Engineering Analysis Centre for Excellence Pvt. Ltd., and that position had attained finality after dismissal of the review petition. Applying that binding law, it upheld the Commissioner (Appeals)' relief and dismissed the revenue's appeal.
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