https://www.taxtmi.com/caselaws?id=396522 Receipts from supply of software as a copyrighted article, without transfer of copyright rights, were treated as business receipts and not royalty under the applicable treaty; the Tribunal followed the assessee's earlier ruling as affirmed by the jurisdictional High Court, so the royalty issue was decided for the assessee. Questions on fixed place, installation and dependent agent permanent establishment were not conclusively determined on the existing record and were remanded to the Assessing Officer for fresh verification; attribution of income and arm's length treatment were to be examined after the permanent establishment finding, leaving those issues open. en-us Thu, 25 Jun 2020 00:00:00 +0530 Wed, 08 Jul 2020 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396522 Receipts from supply of software as a copyrighted article, without transfer of copyright rights, were treated as business receipts and not royalty under the applicable treaty; the Tribunal followed the assessee's earlier ruling as affirmed by the jurisdictional High Court, so the royalty issue was decided for the assessee. Questions on fixed place, installation and dependent agent permanent establishment were not conclusively determined on the existing record and were remanded to the Assessing Officer for fresh verification; attribution of income and arm's length treatment were to be examined after the permanent establishment finding, leaving those issues open. Case-Laws Income Tax Thu, 25 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396522