https://www.taxtmi.com/caselaws?id=411418 Receipts from software licence sales were not royalty because the licences granted only a non-exclusive, non-transferable right to resell or use the programme, without transfer of copyright or any right to reproduce, modify, sublicense, or otherwise exploit it; the royalty addition under the Income-tax Act and the India-Singapore DTAA was deleted. Interest under section 234B was also not leviable because, after deletion of the royalty addition, the tax liability was fully covered by tax deducted at source and no advance tax liability arose on those facts. The assessee obtained relief on the principal issue and the levy of interest was sustained as unwarranted. en-us Mon, 23 Aug 2021 00:00:00 +0530 Wed, 25 Aug 2021 09:09:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411418 Receipts from software licence sales were not royalty because the licences granted only a non-exclusive, non-transferable right to resell or use the programme, without transfer of copyright or any right to reproduce, modify, sublicense, or otherwise exploit it; the royalty addition under the Income-tax Act and the India-Singapore DTAA was deleted. Interest under section 234B was also not leviable because, after deletion of the royalty addition, the tax liability was fully covered by tax deducted at source and no advance tax liability arose on those facts. The assessee obtained relief on the principal issue and the levy of interest was sustained as unwarranted. Case-Laws Income Tax Mon, 23 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411418