https://www.taxtmi.com/caselaws?id=203004 Payments made for purchase of software for onward sale in the Indian market were treated as a trading arrangement, not royalty. On that basis, the payer had no obligation to deduct tax at source, so disallowance under section 40(a)(i) was not justified. The Delhi High Court noted that, because the amount did not have the character of royalty, the withholding provision did not apply and the expenditure could not be disallowed. en-us Tue, 22 Feb 2011 00:00:00 +0530 Wed, 21 Mar 2012 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203004 Payments made for purchase of software for onward sale in the Indian market were treated as a trading arrangement, not royalty. On that basis, the payer had no obligation to deduct tax at source, so disallowance under section 40(a)(i) was not justified. The Delhi High Court noted that, because the amount did not have the character of royalty, the withholding provision did not apply and the expenditure could not be disallowed. Case-Laws Income Tax Tue, 22 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203004