https://www.taxtmi.com/caselaws?id=297376 Receipts from the sale of software were examined to determine whether they constituted royalty under Explanation 2 to Section 9(1)(vi) of the Income-tax Act and Article 12 of the India-Ireland DTAA. The issue was treated as covered by the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd., which held that such receipts do not amount to royalty. Applying that precedent, the software sale receipts were held not taxable as royalty and the question was answered in favour of the assessee and against the Revenue. en-us Tue, 30 Mar 2021 00:00:00 +0530 Tue, 31 Aug 2021 22:17:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297376 Receipts from the sale of software were examined to determine whether they constituted royalty under Explanation 2 to Section 9(1)(vi) of the Income-tax Act and Article 12 of the India-Ireland DTAA. The issue was treated as covered by the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd., which held that such receipts do not amount to royalty. Applying that precedent, the software sale receipts were held not taxable as royalty and the question was answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Tue, 30 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297376