https://www.taxtmi.com/caselaws?id=288960 Consideration for supply of customised software was held not to be royalty under Article 12 of the Indo-US DTAA read with Section 9(1)(vi) because the payment related to a copyrighted article and did not transfer any right in copyright; it was therefore treated as business receipt, subject to the question of business connection or permanent establishment. Interest under Section 234B was also held not chargeable on the facts governed by the earlier binding rulings. Both issues were decided in favour of the assessee and against the Revenue, leaving the Tribunal's order undisturbed. en-us Tue, 25 Apr 2017 00:00:00 +0530 Wed, 08 Jul 2020 10:59:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=288960 Consideration for supply of customised software was held not to be royalty under Article 12 of the Indo-US DTAA read with Section 9(1)(vi) because the payment related to a copyrighted article and did not transfer any right in copyright; it was therefore treated as business receipt, subject to the question of business connection or permanent establishment. Interest under Section 234B was also held not chargeable on the facts governed by the earlier binding rulings. Both issues were decided in favour of the assessee and against the Revenue, leaving the Tribunal's order undisturbed. Case-Laws Income Tax Tue, 25 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=288960