https://www.taxtmi.com/caselaws?id=179570 Payment for supply of software with a licence to use it for business purposes was treated as consideration for a copyrighted article, not a transfer of copyright, so it was not royalty under domestic law or the DTAA. The duplicate-addition issue turned on whether there were two separate payments or one payment with different descriptions, and the matter was remanded to the Assessing Officer for verification. Interest under section 234B was held not exigible on the facts, where the non-resident's income was subject to tax deduction at source. en-us Thu, 08 Oct 2009 00:00:00 +0530 Thu, 09 May 2024 09:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179570 Payment for supply of software with a licence to use it for business purposes was treated as consideration for a copyrighted article, not a transfer of copyright, so it was not royalty under domestic law or the DTAA. The duplicate-addition issue turned on whether there were two separate payments or one payment with different descriptions, and the matter was remanded to the Assessing Officer for verification. Interest under section 234B was held not exigible on the facts, where the non-resident's income was subject to tax deduction at source. Case-Laws Income Tax Thu, 08 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179570