https://www.taxtmi.com/caselaws?id=327188 Receipts from supply of shrink-wrap software to Indian resellers and end users were treated as business receipts, not royalty, because the distribution and end-user licences allowed only use of a copyrighted article and did not transfer any copyright rights such as reproduction, modification, decompilation, or other exploitation of the copyright. On that basis, the consideration did not fall within royalty under the treaty framework. As the supplier had no permanent establishment in India, the receipts were not taxable in India as business income. en-us Thu, 31 Mar 2016 00:00:00 +0530 Thu, 05 May 2016 00:50:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327188 Receipts from supply of shrink-wrap software to Indian resellers and end users were treated as business receipts, not royalty, because the distribution and end-user licences allowed only use of a copyrighted article and did not transfer any copyright rights such as reproduction, modification, decompilation, or other exploitation of the copyright. On that basis, the consideration did not fall within royalty under the treaty framework. As the supplier had no permanent establishment in India, the receipts were not taxable in India as business income. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327188