Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance...
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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TaxTMI 
TaxTMI 
of 4884 
