https://www.taxtmi.com/caselaws?id=383859 Payment for distribution of copyrighted software under a non-exclusive, non-transferable licence was treated as payment for a copyrighted article, not a transfer of copyright rights. On that basis, the India-UK tax treaty did not characterise the payment as royalty, no withholding tax was required under section 195, and the related disallowance under section 40(a)(ia) was deleted. Short credit of TDS was remitted for factual verification and due relief, while interest under sections 234B and 234C was directed to be recomputed on the income ultimately determined. en-us Fri, 26 Jul 2019 00:00:00 +0530 Thu, 01 Aug 2019 06:27:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383859 Payment for distribution of copyrighted software under a non-exclusive, non-transferable licence was treated as payment for a copyrighted article, not a transfer of copyright rights. On that basis, the India-UK tax treaty did not characterise the payment as royalty, no withholding tax was required under section 195, and the related disallowance under section 40(a)(ia) was deleted. Short credit of TDS was remitted for factual verification and due relief, while interest under sections 234B and 234C was directed to be recomputed on the income ultimately determined. Case-Laws Income Tax Fri, 26 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383859