https://www.taxtmi.com/caselaws?id=351191 Payment for a software master copy with rights to modify, alter, amend and resell was treated as royalty because the arrangement went beyond purchase of a copyrighted product and involved use of copyright for further development; the royalty character attracted tax deduction consequences under the Income-tax Act. A disallowance under section 40(a)(ia) was then treated as an addition to the eligible export unit's business profits, so deduction under section 10A was allowed on the enhanced profits. The analysis applied the distinction between acquisition of software ownership and acquisition of copyright rights, and the principle that statutory disallowances increasing eligible profits must be reflected in the deduction computation. en-us Mon, 13 Nov 2017 00:00:00 +0530 Tue, 21 Nov 2017 09:06:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=351191 Payment for a software master copy with rights to modify, alter, amend and resell was treated as royalty because the arrangement went beyond purchase of a copyrighted product and involved use of copyright for further development; the royalty character attracted tax deduction consequences under the Income-tax Act. A disallowance under section 40(a)(ia) was then treated as an addition to the eligible export unit's business profits, so deduction under section 10A was allowed on the enhanced profits. The analysis applied the distinction between acquisition of software ownership and acquisition of copyright rights, and the principle that statutory disallowances increasing eligible profits must be reflected in the deduction computation. Case-Laws Income Tax Mon, 13 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=351191