https://www.taxtmi.com/caselaws?id=415099 Payments for resale or use of computer software under end-user licence or distribution arrangements were treated as non-royalty where no copyright was transferred and no right to reproduce the software was granted. Applying the Supreme Court principle in Engineering Analysis Centre for Excellence Pvt. Ltd., the software receipts, including related support services, retained their character as sale proceeds and did not become royalty merely because support was provided. As a result, the royalty charging provision under section 9(1)(vi) and the withholding requirement under section 195 did not apply, and the addition characterising the receipts as royalty was deleted. en-us Tue, 12 Oct 2021 00:00:00 +0530 Fri, 26 Nov 2021 09:19:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415099 Payments for resale or use of computer software under end-user licence or distribution arrangements were treated as non-royalty where no copyright was transferred and no right to reproduce the software was granted. Applying the Supreme Court principle in Engineering Analysis Centre for Excellence Pvt. Ltd., the software receipts, including related support services, retained their character as sale proceeds and did not become royalty merely because support was provided. As a result, the royalty charging provision under section 9(1)(vi) and the withholding requirement under section 195 did not apply, and the addition characterising the receipts as royalty was deleted. Case-Laws Income Tax Tue, 12 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415099