https://www.taxtmi.com/caselaws?id=409987 The Tribunal dismissed the revenue's appeal, affirming that revenue from software supply by the assessee was not taxable as royalty under the Income Tax Act and India-France DTAA. Previous judicial decisions established that the supply of embedded software did not constitute royalty, emphasizing the integral relationship between software and hardware. The Tribunal held that settled legal positions favored the assessee, rejecting the revenue's arguments regarding retrospective amendments and adequacy of compensation. The judgment upheld that revenue from software supply was not subject to taxation as royalty based on established legal interpretations and precedents. en-us Wed, 30 Jun 2021 00:00:00 +0530 Thu, 22 Jul 2021 08:56:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409987 The Tribunal dismissed the revenue's appeal, affirming that revenue from software supply by the assessee was not taxable as royalty under the Income Tax Act and India-France DTAA. Previous judicial decisions established that the supply of embedded software did not constitute royalty, emphasizing the integral relationship between software and hardware. The Tribunal held that settled legal positions favored the assessee, rejecting the revenue's arguments regarding retrospective amendments and adequacy of compensation. The judgment upheld that revenue from software supply was not subject to taxation as royalty based on established legal interpretations and precedents. Case-Laws Income Tax Wed, 30 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409987