https://www.taxtmi.com/caselaws?id=405359 Payments to non-resident software suppliers for a non-exclusive end-user or distribution licence were treated as consideration for copyrighted software articles, not a transfer of copyright. On that principle, the payments did not constitute royalty under the treaty framework or section 9(1)(vi), and no tax was chargeable in India. As the sums were not taxable as royalty, no obligation to deduct tax at source arose under section 195. The related consequences under sections 201(1), 201(1A) and the disallowance under section 40(a)(ia) could not be sustained. en-us Wed, 17 Mar 2021 00:00:00 +0530 Thu, 18 Mar 2021 09:32:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405359 Payments to non-resident software suppliers for a non-exclusive end-user or distribution licence were treated as consideration for copyrighted software articles, not a transfer of copyright. On that principle, the payments did not constitute royalty under the treaty framework or section 9(1)(vi), and no tax was chargeable in India. As the sums were not taxable as royalty, no obligation to deduct tax at source arose under section 195. The related consequences under sections 201(1), 201(1A) and the disallowance under section 40(a)(ia) could not be sustained. Case-Laws Income Tax Wed, 17 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405359