Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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HC dismissed the revenue's appeal and affirmed the Tribunal's determination that income arising from the sale of software to a UK resident does not constitute "royalty" under the Income Tax Act or the India-UK DTAA. The court held that post-sale support services rendered by the respondent assessee did not effect a transfer of any right in the copyrighted article and therefore did not attract royalty characterization. The HC endorsed the Tribunal's application of the governing Supreme Court precedent, finding no substantial question of law warrants interference. Consequently, the taxpayer's software sale proceeds are not taxable as royalty in India.
HC dismissed the revenue's appeal and affirmed the Tribunal's determination that income arising from the sale of software to a UK resident does not constitute "royalty" under the Income Tax Act or the India-UK DTAA. The court held that post-sale support services rendered by the respondent assessee did not effect a transfer of any right in the copyrighted article and therefore did not attract royalty characterization. The HC endorsed the Tribunal's application of the governing Supreme Court precedent, finding no substantial question of law warrants interference. Consequently, the taxpayer's software sale proceeds are not taxable as royalty in India.
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