https://www.taxtmi.com/caselaws?id=406304 Payments made for resale or use of computer software under distribution agreements or end-user licence agreements were treated as not constituting royalty where no right in the underlying copyright was transferred. Applying the Supreme Court's ruling in Engineering Analysis Centre of Excellence Private Limited, the Madras HC held that such consideration was not taxable as royalty under section 9(1)(vi) of the Income-tax Act, 1961. As the payments were not royalty, no tax deduction at source obligation arose, and the related disallowance under section 40(a)(ia) could not be sustained. The appeals were dismissed and the issue was decided in favour of the assessee. en-us Wed, 07 Apr 2021 00:00:00 +0530 Fri, 09 Apr 2021 18:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406304 Payments made for resale or use of computer software under distribution agreements or end-user licence agreements were treated as not constituting royalty where no right in the underlying copyright was transferred. Applying the Supreme Court's ruling in Engineering Analysis Centre of Excellence Private Limited, the Madras HC held that such consideration was not taxable as royalty under section 9(1)(vi) of the Income-tax Act, 1961. As the payments were not royalty, no tax deduction at source obligation arose, and the related disallowance under section 40(a)(ia) could not be sustained. The appeals were dismissed and the issue was decided in favour of the assessee. Case-Laws Income Tax Wed, 07 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406304