https://www.taxtmi.com/caselaws?id=362681 Receipts from supply of software under a limited licence were held not to constitute royalty, because no copyright rights were transferred and the payer received only a right to use the copyrighted article; the amounts were therefore assessable as business income under the Act and the treaty. The Tribunal also found no fresh factual basis to treat TTI India as a dependent agent permanent establishment, so the corresponding business profits were not taxable in India on that footing. On credit, the Assessing Officer was required to verify and implement the Dispute Resolution Panel's direction. The appeal was thus partly allowed. en-us Wed, 27 Jun 2018 00:00:00 +0530 Fri, 29 Jun 2018 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362681 Receipts from supply of software under a limited licence were held not to constitute royalty, because no copyright rights were transferred and the payer received only a right to use the copyrighted article; the amounts were therefore assessable as business income under the Act and the treaty. The Tribunal also found no fresh factual basis to treat TTI India as a dependent agent permanent establishment, so the corresponding business profits were not taxable in India on that footing. On credit, the Assessing Officer was required to verify and implement the Dispute Resolution Panel's direction. The appeal was thus partly allowed. Case-Laws Income Tax Wed, 27 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362681