https://www.taxtmi.com/caselaws?id=390146 Receipts from software licences were held not to constitute royalty or fees for technical services where the customer received only a limited right to use a copyrighted product, with copyright remaining with the licensor and no right to exploit the copyright itself. The treaty position was treated as more beneficial, and the receipts were characterised as business income; in the absence of a permanent establishment, they were not taxable in India. The delay in filing the appeals was condoned on a liberal, justice-oriented approach, and the disputed TDS credit issue was remanded for verification and grant of the correct credit. en-us Tue, 19 Nov 2019 00:00:00 +0530 Tue, 24 Dec 2019 11:07:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390146 Receipts from software licences were held not to constitute royalty or fees for technical services where the customer received only a limited right to use a copyrighted product, with copyright remaining with the licensor and no right to exploit the copyright itself. The treaty position was treated as more beneficial, and the receipts were characterised as business income; in the absence of a permanent establishment, they were not taxable in India. The delay in filing the appeals was condoned on a liberal, justice-oriented approach, and the disputed TDS credit issue was remanded for verification and grant of the correct credit. Case-Laws Income Tax Tue, 19 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390146