https://www.taxtmi.com/caselaws?id=408949 A payment for software or integrated hardware-software supplies under a distribution arrangement is not royalty where no copyright interest or right to use copyright is transferred. Applying the Supreme Court ruling on software payments, the Tribunal treated the receipts from sales to Indian distributors or customers as non-taxable royalty income in India. Because the receipts were not chargeable to tax as royalty, the tax deduction at source provisions did not apply, and the remaining issues were treated as academic. en-us Mon, 14 Jun 2021 00:00:00 +0530 Fri, 25 Jun 2021 07:13:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408949 A payment for software or integrated hardware-software supplies under a distribution arrangement is not royalty where no copyright interest or right to use copyright is transferred. Applying the Supreme Court ruling on software payments, the Tribunal treated the receipts from sales to Indian distributors or customers as non-taxable royalty income in India. Because the receipts were not chargeable to tax as royalty, the tax deduction at source provisions did not apply, and the remaining issues were treated as academic. Case-Laws Income Tax Mon, 14 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408949