https://www.taxtmi.com/caselaws?id=415025 Receipts from supply of software were treated as consideration for a copyrighted article, not a transfer of copyright, because the issue had already been covered by the assessee's earlier year decisions and the jurisdictional High Court's ruling. On that basis, the consideration was not characterised as royalty under the India-US tax treaty or section 9(1)(vi) of the Income-tax Act, but as business receipts. The software supply payments were therefore not taxable as royalty. en-us Fri, 24 Sep 2021 00:00:00 +0530 Wed, 24 Nov 2021 06:14:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415025 Receipts from supply of software were treated as consideration for a copyrighted article, not a transfer of copyright, because the issue had already been covered by the assessee's earlier year decisions and the jurisdictional High Court's ruling. On that basis, the consideration was not characterised as royalty under the India-US tax treaty or section 9(1)(vi) of the Income-tax Act, but as business receipts. The software supply payments were therefore not taxable as royalty. Case-Laws Income Tax Fri, 24 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415025