https://www.taxtmi.com/caselaws?id=390998 Receipts from sale of shrink-wrapped software were treated as consideration for a copyrighted article, not as consideration for transfer of copyright rights. Applying the assessee's own earlier coordinate bench decisions, the Tribunal held that the receipts did not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-USA DTAA and were therefore not taxable in India. No distinguishing facts for the year under appeal were shown, so the Tribunal followed its consistent prior view and allowed the appeal. en-us Fri, 10 Jan 2020 00:00:00 +0530 Thu, 16 Jan 2020 19:03:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390998 Receipts from sale of shrink-wrapped software were treated as consideration for a copyrighted article, not as consideration for transfer of copyright rights. Applying the assessee's own earlier coordinate bench decisions, the Tribunal held that the receipts did not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-USA DTAA and were therefore not taxable in India. No distinguishing facts for the year under appeal were shown, so the Tribunal followed its consistent prior view and allowed the appeal. Case-Laws Income Tax Fri, 10 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390998