https://www.taxtmi.com/caselaws?id=406529 Consideration received for the resale or use of computer software under a licence or distribution arrangement was held not to be royalty, because such payments do not confer any interest in, or right to use, copyright itself. Applying the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd., the receipts were treated as outside the royalty provisions of the Income-tax Act and the applicable treaty. On that basis, the software licence receipts were not taxable as royalty in India, and the addition made by the Revenue was deleted. en-us Thu, 15 Apr 2021 00:00:00 +0530 Fri, 16 Apr 2021 08:56:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406529 Consideration received for the resale or use of computer software under a licence or distribution arrangement was held not to be royalty, because such payments do not confer any interest in, or right to use, copyright itself. Applying the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd., the receipts were treated as outside the royalty provisions of the Income-tax Act and the applicable treaty. On that basis, the software licence receipts were not taxable as royalty in India, and the addition made by the Revenue was deleted. Case-Laws Income Tax Thu, 15 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406529