https://www.taxtmi.com/caselaws?id=122385 Consideration for shrink-wrap software supplied under end-user licence terms is not royalty under Article 12(3) of the Indo-US DTAA where neither distributors nor users receive rights to reproduce, modify, decompile, reverse engineer, or otherwise exploit copyright. The transaction is a sale of a copyrighted article and is not taxable in India as royalty. Interest for shortfall in advance tax under Section 234B is not leviable on a non-resident where the entire Indian income is subject to tax deduction at source, because deductible tax must be reduced in computing advance-tax liability. 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 shrink-wrap software supplied under end-user licence terms is not royalty under Article 12(3) of the Indo-US DTAA where neither distributors nor users receive rights to reproduce, modify, decompile, reverse engineer, or otherwise exploit copyright. The transaction is a sale of a copyrighted article and is not taxable in India as royalty. Interest for shortfall in advance tax under Section 234B is not leviable on a non-resident where the entire Indian income is subject to tax deduction at source, because deductible tax must be reduced in computing advance-tax liability. Case-Laws Income Tax Thu, 01 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122385