https://www.taxtmi.com/caselaws?id=183260 Payments for standard software acquired for internal operational use under a non-exclusive, perpetual, irrevocable and royalty-free licence were treated as consideration for a copyrighted article, not royalty. Because the purchaser received no right to exploit, modify, sublicense, reverse engineer or otherwise exercise rights in the underlying copyright, the amount fell outside the domestic and treaty definitions of royalty. In the absence of a permanent establishment in India, the foreign suppliers' receipts were not taxable as business profits, and no tax was deductible at source under section 195. en-us Fri, 26 Nov 2010 00:00:00 +0530 Fri, 03 Jun 2016 11:19:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=183260 Payments for standard software acquired for internal operational use under a non-exclusive, perpetual, irrevocable and royalty-free licence were treated as consideration for a copyrighted article, not royalty. Because the purchaser received no right to exploit, modify, sublicense, reverse engineer or otherwise exercise rights in the underlying copyright, the amount fell outside the domestic and treaty definitions of royalty. In the absence of a permanent establishment in India, the foreign suppliers' receipts were not taxable as business profits, and no tax was deductible at source under section 195. Case-Laws Income Tax Fri, 26 Nov 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183260