https://www.taxtmi.com/caselaws?id=382595 Receipts under a non-exclusive, limited software licence were treated as consideration for use of a copyrighted article, not a transfer of copyright or the right to exploit copyright, so they did not constitute royalty under section 9(1)(vi) or Article 12 of the India-USA DTAA. Applying its earlier decision and the jurisdictional High Court's view, the Tribunal also held that the Test Tools Agreement was inseparable from the principal BREW arrangement and likewise not independently taxable as royalty. The assessee therefore succeeded on the substantive tax issue. en-us Mon, 01 Jul 2019 00:00:00 +0530 Tue, 06 Aug 2019 17:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=382595 Receipts under a non-exclusive, limited software licence were treated as consideration for use of a copyrighted article, not a transfer of copyright or the right to exploit copyright, so they did not constitute royalty under section 9(1)(vi) or Article 12 of the India-USA DTAA. Applying its earlier decision and the jurisdictional High Court's view, the Tribunal also held that the Test Tools Agreement was inseparable from the principal BREW arrangement and likewise not independently taxable as royalty. The assessee therefore succeeded on the substantive tax issue. Case-Laws Income Tax Mon, 01 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=382595