https://www.taxtmi.com/caselaws?id=207919 Offshore supply of hardware and embedded software by a non-resident was treated as a principal-to-principal sale completed outside India, with title and risk passing abroad; on those facts, no business connection or India-based operations generated taxable income under section 9(1)(i). The software component was held to be a copyrighted article forming part of the supplied GSM system, not a transfer of copyright rights, so it did not constitute royalty under section 9(1)(vi) or the treaty provision. Interest under section 234B was held not leviable because the non-resident had no advance-tax obligation where tax was deductible at source. The notice under section 142(1) was upheld after the validating amendment. en-us Fri, 23 Dec 2011 00:00:00 +0530 Mon, 16 Feb 2026 11:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207919 Offshore supply of hardware and embedded software by a non-resident was treated as a principal-to-principal sale completed outside India, with title and risk passing abroad; on those facts, no business connection or India-based operations generated taxable income under section 9(1)(i). The software component was held to be a copyrighted article forming part of the supplied GSM system, not a transfer of copyright rights, so it did not constitute royalty under section 9(1)(vi) or the treaty provision. Interest under section 234B was held not leviable because the non-resident had no advance-tax obligation where tax was deductible at source. The notice under section 142(1) was upheld after the validating amendment. Case-Laws Income Tax Fri, 23 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207919