https://www.taxtmi.com/caselaws?id=387028 Offshore supply receipts of a non-resident were held not taxable in India because title and risk passed outside India, consideration was received offshore, and the Revenue failed to establish any business connection or taxable PE, including a fixed place, installation, liaison office or dependent agent PE. Interest under section 234B was not leviable because the tax deduction obligation lay on the payer, not the non-resident assessee. Consideration for supplied software was also held not taxable as royalty, as the transaction was treated as sale of a copyrighted article and not a transfer of copyright rights or a licence to exploit copyright. en-us Mon, 30 Sep 2019 00:00:00 +0530 Tue, 15 Oct 2019 12:31:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=387028 Offshore supply receipts of a non-resident were held not taxable in India because title and risk passed outside India, consideration was received offshore, and the Revenue failed to establish any business connection or taxable PE, including a fixed place, installation, liaison office or dependent agent PE. Interest under section 234B was not leviable because the tax deduction obligation lay on the payer, not the non-resident assessee. Consideration for supplied software was also held not taxable as royalty, as the transaction was treated as sale of a copyrighted article and not a transfer of copyright rights or a licence to exploit copyright. Case-Laws Income Tax Mon, 30 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=387028