https://www.taxtmi.com/caselaws?id=122385 Consideration for supply of shrink-wrap software was treated as payment for a copyrighted article, not as royalty under Article 12(3) of the Indo-US DTAA, because no right to reproduce, modify, decompile, reverse engineer, or otherwise exploit copyright was transferred. The note also states that interest under Section 234B is not leviable on a non-resident where the Indian income is subject to tax deduction at source, since advance tax liability is computed after reducing tax deductible at source and no advance tax shortfall survives. The revenue's appeal failed on both issues. en-us Thu, 01 Apr 2010 00:00:00 +0530 Sat, 19 Aug 2023 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122385 Consideration for supply of shrink-wrap software was treated as payment for a copyrighted article, not as royalty under Article 12(3) of the Indo-US DTAA, because no right to reproduce, modify, decompile, reverse engineer, or otherwise exploit copyright was transferred. The note also states that interest under Section 234B is not leviable on a non-resident where the Indian income is subject to tax deduction at source, since advance tax liability is computed after reducing tax deductible at source and no advance tax shortfall survives. The revenue's appeal failed on both issues. Case-Laws Income Tax Thu, 01 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122385