https://www.taxtmi.com/caselaws?id=189856 The Tribunal allowed the appeal, holding that payments for the purchase of software for resale do not constitute 'royalty' under Section 9(1)(vi) and thus do not attract TDS under Section 194J. The disallowance under Section 40(a)(ia) was deleted, with the Tribunal concluding that the assessee acted as a distributor or trader of the software without acquiring any rights to use or modify it. The decision was based on distinguishing between payments for acquiring the right to use software and payments for purchasing software as a product. en-us Wed, 15 Jun 2016 00:00:00 +0530 Mon, 23 Jan 2017 17:46:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189856 The Tribunal allowed the appeal, holding that payments for the purchase of software for resale do not constitute 'royalty' under Section 9(1)(vi) and thus do not attract TDS under Section 194J. The disallowance under Section 40(a)(ia) was deleted, with the Tribunal concluding that the assessee acted as a distributor or trader of the software without acquiring any rights to use or modify it. The decision was based on distinguishing between payments for acquiring the right to use software and payments for purchasing software as a product. Case-Laws Income Tax Wed, 15 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189856