https://www.taxtmi.com/caselaws?id=401604 Receipts from sale of software were held not to be royalty under the India-UK DTAA because the payment was for purchase of a copyrighted product on a principal-to-principal basis, without transfer of copyright rights; the issue was decided in favour of the assessee. Explanation 4 to section 9(1)(vi) of the Income-tax Act did not alter the treaty position under Article 13, as a domestic amendment cannot enlarge the scope of royalty under an unamended treaty; this issue was also decided in favour of the assessee. The appeals were dismissed, as no substantial question of law arose. en-us Tue, 24 Nov 2020 00:00:00 +0530 Sat, 20 Feb 2021 12:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401604 Receipts from sale of software were held not to be royalty under the India-UK DTAA because the payment was for purchase of a copyrighted product on a principal-to-principal basis, without transfer of copyright rights; the issue was decided in favour of the assessee. Explanation 4 to section 9(1)(vi) of the Income-tax Act did not alter the treaty position under Article 13, as a domestic amendment cannot enlarge the scope of royalty under an unamended treaty; this issue was also decided in favour of the assessee. The appeals were dismissed, as no substantial question of law arose. Case-Laws Income Tax Tue, 24 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401604