https://www.taxtmi.com/caselaws?id=336708 The Tribunal partially allowed both appeals, ruling in favor of the assessee regarding the re-characterization of income from software licensing as business income rather than royalty. The Tribunal held that the income from the sale of software licenses constituted business profits under the DTAA and was not taxable as royalty. The appellant's contentions on being the beneficial owner of the income and the taxation of income from maintenance services were dismissed as infructuous following the decision on the re-characterization issue. en-us Wed, 21 Dec 2016 00:00:00 +0530 Tue, 07 Feb 2017 13:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336708 The Tribunal partially allowed both appeals, ruling in favor of the assessee regarding the re-characterization of income from software licensing as business income rather than royalty. The Tribunal held that the income from the sale of software licenses constituted business profits under the DTAA and was not taxable as royalty. The appellant's contentions on being the beneficial owner of the income and the taxation of income from maintenance services were dismissed as infructuous following the decision on the re-characterization issue. Case-Laws Income Tax Wed, 21 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336708