https://www.taxtmi.com/caselaws?id=183259 The Tribunal upheld the first appellate authority's decision that the payment for software purchase was business income, not royalty, as the supplier did not have a Permanent Establishment in India. The Tribunal cited precedents to support that software purchase payments are not considered royalty under the Income-tax Act or the DTAA. Consequently, the assessee's income was deemed non-taxable in India, leading to the dismissal of Revenue's appeals. 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=183259 The Tribunal upheld the first appellate authority's decision that the payment for software purchase was business income, not royalty, as the supplier did not have a Permanent Establishment in India. The Tribunal cited precedents to support that software purchase payments are not considered royalty under the Income-tax Act or the DTAA. Consequently, the assessee's income was deemed non-taxable in India, leading to the dismissal of Revenue's appeals. Case-Laws Income Tax Fri, 26 Nov 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183259