https://www.taxtmi.com/caselaws?id=325029 Payments for a non-exclusive, non-transferable software licence and maintenance were treated as royalty because the assessee acquired the right to use software rather than a mere copyrighted article, so tax had to be withheld under section 195. Dedicated bandwidth charges were also characterised as royalty, as they were considered consideration for use of a process and a facility under section 9(1)(vi) and the DTAA, again attracting withholding. Amounts routed as reimbursements were not proved to be pure reimbursements with proper segregation and supporting records, so they were taxed according to their underlying character and subjected to deduction at source. en-us Mon, 15 Feb 2016 00:00:00 +0530 Tue, 08 Mar 2016 11:03:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325029 Payments for a non-exclusive, non-transferable software licence and maintenance were treated as royalty because the assessee acquired the right to use software rather than a mere copyrighted article, so tax had to be withheld under section 195. Dedicated bandwidth charges were also characterised as royalty, as they were considered consideration for use of a process and a facility under section 9(1)(vi) and the DTAA, again attracting withholding. Amounts routed as reimbursements were not proved to be pure reimbursements with proper segregation and supporting records, so they were taxed according to their underlying character and subjected to deduction at source. Case-Laws Income Tax Mon, 15 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325029