https://www.taxtmi.com/caselaws?id=412462 Consideration paid to a non-resident for supply of computer software is not royalty where there is no transfer of copyright rights in the software. Applying the Supreme Court ruling in Engineering Analysis, the payment for software supplied to meet the assessee's specific requirements did not attract the royalty characterisation. As a result, no tax was deductible at source under section 195, and the earlier revenue view treating such remittance as royalty was no longer good law for these transactions. en-us Thu, 16 Sep 2021 00:00:00 +0530 Sat, 18 Sep 2021 08:10:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412462 Consideration paid to a non-resident for supply of computer software is not royalty where there is no transfer of copyright rights in the software. Applying the Supreme Court ruling in Engineering Analysis, the payment for software supplied to meet the assessee's specific requirements did not attract the royalty characterisation. As a result, no tax was deductible at source under section 195, and the earlier revenue view treating such remittance as royalty was no longer good law for these transactions. Case-Laws Income Tax Thu, 16 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412462