https://www.taxtmi.com/caselaws?id=336897 Software supply receipts are characterised as business income rather than royalty where the customer receives only limited use rights, copyright ownership remains with the supplier, and no effective source code transfer occurs. A dependent agent permanent establishment is not established on a principal-to-principal arrangement absent authority to conclude contracts or sufficient dependence. Expense reimbursements are not fees for technical services unless they make available technical knowledge, skill, know-how, or process. Interest under section 234B is generally not leviable on a non-resident where the income is subject to withholding, applying the relevant treaty and precedent-based position. en-us Wed, 30 Nov 2016 00:00:00 +0530 Fri, 30 Dec 2016 17:25:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336897 Software supply receipts are characterised as business income rather than royalty where the customer receives only limited use rights, copyright ownership remains with the supplier, and no effective source code transfer occurs. A dependent agent permanent establishment is not established on a principal-to-principal arrangement absent authority to conclude contracts or sufficient dependence. Expense reimbursements are not fees for technical services unless they make available technical knowledge, skill, know-how, or process. Interest under section 234B is generally not leviable on a non-resident where the income is subject to withholding, applying the relevant treaty and precedent-based position. Case-Laws Income Tax Wed, 30 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336897