https://www.taxtmi.com/caselaws?id=414806 Consideration paid by resident distributors or end-users to non-resident software suppliers for resale or use of computer software was treated as not constituting royalty for use of copyright, so no income arose in India on that basis and no tax deduction obligation under Section 195 followed. On that legal position, the basis for reopening an assessment under Section 147 could not survive. The Madras High Court therefore treated the reassessment challenge as unsustainable in law and answered the issue in favour of the assessee. en-us Fri, 03 Sep 2021 00:00:00 +0530 Wed, 17 Nov 2021 10:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414806 Consideration paid by resident distributors or end-users to non-resident software suppliers for resale or use of computer software was treated as not constituting royalty for use of copyright, so no income arose in India on that basis and no tax deduction obligation under Section 195 followed. On that legal position, the basis for reopening an assessment under Section 147 could not survive. The Madras High Court therefore treated the reassessment challenge as unsustainable in law and answered the issue in favour of the assessee. Case-Laws Income Tax Fri, 03 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414806