https://www.taxtmi.com/caselaws?id=406800 Consideration received under software distribution and end-user licence arrangements does not amount to royalty where no copyright right or interest is transferred, following the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd. Applying that binding principle, the ITAT held that receipts from software licence sales under the India-Australia treaty framework were not taxable as royalty under section 9(1)(vi) of the Income-tax Act. The royalty additions were therefore deleted, and the assessee's receipts were treated as outside the royalty charge. en-us Thu, 22 Apr 2021 00:00:00 +0530 Wed, 28 Jul 2021 18:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406800 Consideration received under software distribution and end-user licence arrangements does not amount to royalty where no copyright right or interest is transferred, following the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd. Applying that binding principle, the ITAT held that receipts from software licence sales under the India-Australia treaty framework were not taxable as royalty under section 9(1)(vi) of the Income-tax Act. The royalty additions were therefore deleted, and the assessee's receipts were treated as outside the royalty charge. Case-Laws Income Tax Thu, 22 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406800