https://www.taxtmi.com/caselaws?id=280397 Consideration for a non-exclusive, non-transferable software licence was treated as payment for a copyrighted article, not for the transfer or exploitation of copyright, so it was not taxable as royalty. The Tribunal also held that penalty for concealment or inaccurate particulars could not survive once the underlying quantum addition was deleted, as the claim was made on a bona fide legal understanding and no deliberate concealment was found. The issue whether a permanent establishment existed through value added resellers was not decided on merits and was remanded for fresh adjudication by the first appellate authority. en-us Fri, 31 Mar 2017 00:00:00 +0530 Fri, 03 May 2019 09:26:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280397 Consideration for a non-exclusive, non-transferable software licence was treated as payment for a copyrighted article, not for the transfer or exploitation of copyright, so it was not taxable as royalty. The Tribunal also held that penalty for concealment or inaccurate particulars could not survive once the underlying quantum addition was deleted, as the claim was made on a bona fide legal understanding and no deliberate concealment was found. The issue whether a permanent establishment existed through value added resellers was not decided on merits and was remanded for fresh adjudication by the first appellate authority. Case-Laws Income Tax Fri, 31 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280397