https://www.taxtmi.com/caselaws?id=409716 Payment for software purchased from a non-resident was treated as consideration for a sale of goods containing embedded computer code, not as royalty, because no right in or transfer of copyright was shown. Applying the Supreme Court principle on software distribution and end-user licence arrangements, the payment was held not chargeable as royalty under the treaty or the domestic royalty provision. As no income chargeable to tax in India arose on the transaction, the obligation to deduct tax at source under section 195 did not arise, and no TDS liability attached. en-us Fri, 02 Jul 2021 00:00:00 +0530 Thu, 15 Jul 2021 08:02:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409716 Payment for software purchased from a non-resident was treated as consideration for a sale of goods containing embedded computer code, not as royalty, because no right in or transfer of copyright was shown. Applying the Supreme Court principle on software distribution and end-user licence arrangements, the payment was held not chargeable as royalty under the treaty or the domestic royalty provision. As no income chargeable to tax in India arose on the transaction, the obligation to deduct tax at source under section 195 did not arise, and no TDS liability attached. Case-Laws Income Tax Fri, 02 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409716