https://www.taxtmi.com/caselaws?id=122369 Consideration for supply of software under a restricted licence was treated as payment for a copyrighted article, not for transfer of any part of the underlying copyright. The licence permitted use of the software in the purchaser's network but prohibited duplication, modification, reverse engineering, sublicensing, assignment, or other exploitation of copyright rights. Applying the distinction between copyright and copyrighted article under the Copyright Act, 1957, and the more beneficial DTAA treatment, the payment was held not to be royalty under Article 12(3) of the DTAA or section 9(1)(vi). The related addition was deleted. en-us Tue, 13 Apr 2010 00:00:00 +0530 Mon, 13 Aug 2012 12:43:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122369 Consideration for supply of software under a restricted licence was treated as payment for a copyrighted article, not for transfer of any part of the underlying copyright. The licence permitted use of the software in the purchaser's network but prohibited duplication, modification, reverse engineering, sublicensing, assignment, or other exploitation of copyright rights. Applying the distinction between copyright and copyrighted article under the Copyright Act, 1957, and the more beneficial DTAA treatment, the payment was held not to be royalty under Article 12(3) of the DTAA or section 9(1)(vi). The related addition was deleted. Case-Laws Income Tax Tue, 13 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122369