https://www.taxtmi.com/caselaws?id=204035 Consideration paid for a non-exclusive, non-transferable software licence was analysed under the India-Singapore tax treaty and the Income-tax Act, 1961. The arrangement granted only a right to use the software for internal business purposes, without any transfer of copyright or ownership in the software. Applying the distinction between a copyrighted article and rights in copyright, the payment was treated as purchase of a copyrighted article rather than royalty for use of, or the right to use, copyright. It was therefore not taxable in India as royalty, and no tax was deductible at source under section 195. en-us Tue, 22 Jun 2010 00:00:00 +0530 Thu, 09 Aug 2012 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204035 Consideration paid for a non-exclusive, non-transferable software licence was analysed under the India-Singapore tax treaty and the Income-tax Act, 1961. The arrangement granted only a right to use the software for internal business purposes, without any transfer of copyright or ownership in the software. Applying the distinction between a copyrighted article and rights in copyright, the payment was treated as purchase of a copyrighted article rather than royalty for use of, or the right to use, copyright. It was therefore not taxable in India as royalty, and no tax was deductible at source under section 195. Case-Laws Income Tax Tue, 22 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204035