https://www.taxtmi.com/caselaws?id=413603 Receipts from sale of software licences to Indian customers were analysed under section 9(1)(vi) of the Income-tax Act and the India-Netherlands DTAA. The agreements granted only a non-exclusive, non-transferable right to use and resell software, with express limits on copying, modification, reverse engineering, sublicensing, and any transfer of copyright. Because no interest in, or right to use, copyright was transferred, the receipts were not characterised as royalty under either the treaty definition or the domestic royalty provision. The addition treating the software receipts as royalty was deleted. en-us Thu, 30 Sep 2021 00:00:00 +0530 Sat, 16 Oct 2021 09:05:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413603 Receipts from sale of software licences to Indian customers were analysed under section 9(1)(vi) of the Income-tax Act and the India-Netherlands DTAA. The agreements granted only a non-exclusive, non-transferable right to use and resell software, with express limits on copying, modification, reverse engineering, sublicensing, and any transfer of copyright. Because no interest in, or right to use, copyright was transferred, the receipts were not characterised as royalty under either the treaty definition or the domestic royalty provision. The addition treating the software receipts as royalty was deleted. Case-Laws Income Tax Thu, 30 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413603