https://www.taxtmi.com/caselaws?id=231266 Payments for shrink-wrap and download software were treated as royalty because the licence transferred more than a physical copy: it permitted use of software and copying or storing it for internal business purposes, which the Tribunal viewed as rights forming part of copyright under the Income-tax Act and the treaty. The earlier order relied on by the assessee was found inapplicable on the facts because the present matter had already been examined under both the treaty and the Act. The payments were therefore royalty, tax was required to be deducted at source, and the disallowance was upheld. en-us Tue, 12 Jun 2012 00:00:00 +0530 Wed, 24 Apr 2013 13:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=231266 Payments for shrink-wrap and download software were treated as royalty because the licence transferred more than a physical copy: it permitted use of software and copying or storing it for internal business purposes, which the Tribunal viewed as rights forming part of copyright under the Income-tax Act and the treaty. The earlier order relied on by the assessee was found inapplicable on the facts because the present matter had already been examined under both the treaty and the Act. The payments were therefore royalty, tax was required to be deducted at source, and the disallowance was upheld. Case-Laws Income Tax Tue, 12 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=231266