https://www.taxtmi.com/caselaws?id=327974 A non-exclusive, non-transferable software licence that leaves ownership and copyright with the supplier transfers only a copyrighted article, not copyright rights; the consideration is therefore not royalty under the treaty and is taxable as business income under Article 7. The retrospective domestic amendment to section 9(1)(vi) does not change the treaty position absent a corresponding treaty amendment. Credit for tax deducted at source was directed to be verified by the Assessing Officer and granted in accordance with law on remand. en-us Tue, 12 Apr 2016 00:00:00 +0530 Fri, 20 May 2016 02:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327974 A non-exclusive, non-transferable software licence that leaves ownership and copyright with the supplier transfers only a copyrighted article, not copyright rights; the consideration is therefore not royalty under the treaty and is taxable as business income under Article 7. The retrospective domestic amendment to section 9(1)(vi) does not change the treaty position absent a corresponding treaty amendment. Credit for tax deducted at source was directed to be verified by the Assessing Officer and granted in accordance with law on remand. Case-Laws Income Tax Tue, 12 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327974