https://www.taxtmi.com/caselaws?id=327827 Payments for acquisition of software for onward supply and installation, where no source code or right to exploit the copyright was transferred, were treated as purchase consideration and not royalty; section 195 withholding was therefore not attracted. Annual maintenance service payments were not finally disallowed under section 40(a)(ia) because the Tribunal required verification of whether the remittance and tax deduction had occurred in the following year, and relief would follow if that factual position was confirmed. The assessee obtained relief on the software-payment issue, with only limited remand on the maintenance-payment issue. en-us Fri, 29 Apr 2016 00:00:00 +0530 Fri, 20 May 2016 13:19:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327827 Payments for acquisition of software for onward supply and installation, where no source code or right to exploit the copyright was transferred, were treated as purchase consideration and not royalty; section 195 withholding was therefore not attracted. Annual maintenance service payments were not finally disallowed under section 40(a)(ia) because the Tribunal required verification of whether the remittance and tax deduction had occurred in the following year, and relief would follow if that factual position was confirmed. The assessee obtained relief on the software-payment issue, with only limited remand on the maintenance-payment issue. Case-Laws Income Tax Fri, 29 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327827