https://www.taxtmi.com/caselaws?id=348895 Software licence payments were treated as consideration for a copyrighted article, not royalty, so withholding failure did not justify disallowance. Guarantee commission was recognised on a spread-over-the-period basis, consistent with the assessee's earlier years. Data communication and software billing allocations were treated as pure reimbursements without mark-up, and therefore not as royalty or fees for technical services. Interest paid by the Indian permanent establishment to head office and overseas branches was held to be payment to self and not taxable in India. The section 14A issue on that related interest was remitted for fresh examination. en-us Mon, 11 Sep 2017 00:00:00 +0530 Mon, 02 Oct 2017 19:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=348895 Software licence payments were treated as consideration for a copyrighted article, not royalty, so withholding failure did not justify disallowance. Guarantee commission was recognised on a spread-over-the-period basis, consistent with the assessee's earlier years. Data communication and software billing allocations were treated as pure reimbursements without mark-up, and therefore not as royalty or fees for technical services. Interest paid by the Indian permanent establishment to head office and overseas branches was held to be payment to self and not taxable in India. The section 14A issue on that related interest was remitted for fresh examination. Case-Laws Income Tax Mon, 11 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=348895