https://www.taxtmi.com/caselaws?id=208537 The High Court ruled in favor of the revenue, holding that payments made for software purchases constituted royalty and were taxable in India under Section 9(1)(vi) of the Income Tax Act and the Double Taxation Agreement. The Court set aside the ITAT's orders, restoring the decisions of the appellate authority and the assessing officer. The Court emphasized the separate nature of software supply and hardware integration transactions, determining that the payments were indeed royalty. en-us Fri, 21 Oct 2011 00:00:00 +0530 Thu, 07 Apr 2016 15:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208537 The High Court ruled in favor of the revenue, holding that payments made for software purchases constituted royalty and were taxable in India under Section 9(1)(vi) of the Income Tax Act and the Double Taxation Agreement. The Court set aside the ITAT's orders, restoring the decisions of the appellate authority and the assessing officer. The Court emphasized the separate nature of software supply and hardware integration transactions, determining that the payments were indeed royalty. Case-Laws Income Tax Fri, 21 Oct 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208537