https://www.taxtmi.com/caselaws?id=259557 Consideration for software supplied as an embedded component of hardware was treated as payment for goods, not royalty, because the software had no independent existence and merely enabled the equipment to function. Where the hardware and software were supplied as a composite unit, the payment could not be characterised as a separate licence fee or brought to tax under both domestic royalty provisions and the applicable treaty. On those facts, section 9(1)(vi) was not attracted, and the embedded software receipts were outside royalty taxation. en-us Fri, 27 Feb 2015 00:00:00 +0530 Fri, 14 Aug 2015 15:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259557 Consideration for software supplied as an embedded component of hardware was treated as payment for goods, not royalty, because the software had no independent existence and merely enabled the equipment to function. Where the hardware and software were supplied as a composite unit, the payment could not be characterised as a separate licence fee or brought to tax under both domestic royalty provisions and the applicable treaty. On those facts, section 9(1)(vi) was not attracted, and the embedded software receipts were outside royalty taxation. Case-Laws Income Tax Fri, 27 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259557