https://www.taxtmi.com/caselaws?id=173820 Consideration paid for connectivity facility and maintenance of co-located equipment was treated as royalty because the foreign entity permitted use of industrial, commercial or scientific equipment, bringing the payment within the expanded domestic royalty definition and the treaty royalty article; tax was therefore deductible at source. Payments for use of True Dial software under a limited, non-exclusive licence were also treated as royalty because the arrangement conveyed only a restricted right to use the software, while ownership and intellectual property remained with the licensor; tax was therefore deductible at source. The combined effect was that both categories of payments were chargeable to tax in India as royalty, sustaining the deduction obligation. en-us Fri, 03 Aug 2007 00:00:00 +0530 Wed, 18 Dec 2024 15:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=173820 Consideration paid for connectivity facility and maintenance of co-located equipment was treated as royalty because the foreign entity permitted use of industrial, commercial or scientific equipment, bringing the payment within the expanded domestic royalty definition and the treaty royalty article; tax was therefore deductible at source. Payments for use of True Dial software under a limited, non-exclusive licence were also treated as royalty because the arrangement conveyed only a restricted right to use the software, while ownership and intellectual property remained with the licensor; tax was therefore deductible at source. The combined effect was that both categories of payments were chargeable to tax in India as royalty, sustaining the deduction obligation. Case-Laws Income Tax Fri, 03 Aug 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=173820