https://www.taxtmi.com/caselaws?id=330663 The Tribunal held that the payment for shrink-wrapped readymade software did not constitute royalty under Section 9(1)(vi) of the Income Tax Act and was not subject to TDS under Section 195. The retrospective amendments introduced by the Finance Act, 2012, were not applicable to the payment made before the amendments. The Double Taxation Avoidance Agreement between India and Singapore exempted the payment from tax deduction at source. Therefore, the appeal by the assessee was allowed, and the demand raised by the Assessing Officer was canceled. en-us Tue, 26 Jul 2016 00:00:00 +0530 Tue, 02 Aug 2016 11:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330663 The Tribunal held that the payment for shrink-wrapped readymade software did not constitute royalty under Section 9(1)(vi) of the Income Tax Act and was not subject to TDS under Section 195. The retrospective amendments introduced by the Finance Act, 2012, were not applicable to the payment made before the amendments. The Double Taxation Avoidance Agreement between India and Singapore exempted the payment from tax deduction at source. Therefore, the appeal by the assessee was allowed, and the demand raised by the Assessing Officer was canceled. Case-Laws Income Tax Tue, 26 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330663