https://www.taxtmi.com/caselaws?id=123032 Software supplied under a perpetual, irrevocable, non-exclusive licence was treated as consideration for sale of a copyright article, because copyright remained with the assessee and the agreement did not transfer copyright rights. Applying the same contractual terms as in the earlier year, the Tribunal held that the receipt did not constitute royalty under Article 12(3) of the India-USA DTAA. The payment was therefore not taxable as royalty on that basis. en-us Fri, 25 Jun 2010 00:00:00 +0530 Thu, 30 Aug 2012 10:49:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=123032 Software supplied under a perpetual, irrevocable, non-exclusive licence was treated as consideration for sale of a copyright article, because copyright remained with the assessee and the agreement did not transfer copyright rights. Applying the same contractual terms as in the earlier year, the Tribunal held that the receipt did not constitute royalty under Article 12(3) of the India-USA DTAA. The payment was therefore not taxable as royalty on that basis. Case-Laws Income Tax Fri, 25 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=123032