https://www.taxtmi.com/caselaws?id=262131 Payments for software licences required determination of whether the rights acquired amounted to royalty or merely purchase of copyrighted articles. The existing findings were insufficient because the licence agreements had not been examined against their contractual terms, and the widened domestic definition of royalty, together with the relevant treaty position, had to be considered. The matter was therefore remitted for fresh adjudication on merits after examining the agreements and giving the assessee a proper opportunity of hearing. en-us Wed, 29 Jul 2015 00:00:00 +0530 Mon, 07 Aug 2023 12:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262131 Payments for software licences required determination of whether the rights acquired amounted to royalty or merely purchase of copyrighted articles. The existing findings were insufficient because the licence agreements had not been examined against their contractual terms, and the widened domestic definition of royalty, together with the relevant treaty position, had to be considered. The matter was therefore remitted for fresh adjudication on merits after examining the agreements and giving the assessee a proper opportunity of hearing. Case-Laws Income Tax Wed, 29 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262131