https://www.taxtmi.com/caselaws?id=325356 Receipts from software sales were held not to be royalty under the DTAA because the transaction transferred only a right to use the product, not copyright, and a retrospective domestic amendment could not expand the treaty definition. The connected annual maintenance charges were treated on the same footing and also assessed as business profits. Training fees for software users were likewise held to fall outside fees for technical services, as they were ancillary to the software transaction and covered by the business profits article. An estimated addition on consultancy receipts and miscellaneous income was deleted because the books were not rejected and no defects were shown. en-us Mon, 14 Mar 2016 00:00:00 +0530 Sat, 04 Jun 2016 15:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325356 Receipts from software sales were held not to be royalty under the DTAA because the transaction transferred only a right to use the product, not copyright, and a retrospective domestic amendment could not expand the treaty definition. The connected annual maintenance charges were treated on the same footing and also assessed as business profits. Training fees for software users were likewise held to fall outside fees for technical services, as they were ancillary to the software transaction and covered by the business profits article. An estimated addition on consultancy receipts and miscellaneous income was deleted because the books were not rejected and no defects were shown. Case-Laws Income Tax Mon, 14 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325356