https://www.taxtmi.com/caselaws?id=397945 Consideration for sale of software licences was treated as payment for a copyrighted article, not royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-Singapore DTAA. The licences were non-exclusive and non-transferable, and customers obtained only restricted internal-use rights without any transfer of copyright or commercially exploitable rights. Domestic law amendments expanding the royalty definition could not enlarge the narrower treaty meaning, which remained applicable because it was more beneficial to the assessee. The receipt was therefore held not to be taxable as royalty. en-us Mon, 31 Aug 2020 00:00:00 +0530 Mon, 18 Jan 2021 14:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397945 Consideration for sale of software licences was treated as payment for a copyrighted article, not royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-Singapore DTAA. The licences were non-exclusive and non-transferable, and customers obtained only restricted internal-use rights without any transfer of copyright or commercially exploitable rights. Domestic law amendments expanding the royalty definition could not enlarge the narrower treaty meaning, which remained applicable because it was more beneficial to the assessee. The receipt was therefore held not to be taxable as royalty. Case-Laws Income Tax Mon, 31 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397945