https://www.taxtmi.com/caselaws?id=418062 Amounts received for WAN connectivity and bandwidth services were treated as non-taxable royalty because the customer obtained only a transmission and no possessory, operational, or treaty-covered right in the network, equipment, or process; the narrower India-UK DTAA definition prevailed over the wider domestic expansion. Amounts received for shrink-wrapped software were also held not to be royalty because the transaction involved a copyrighted article for end use, with no transfer of copyright rights or interest. On that reasoning, the disputed receipts could not be brought to tax in India as royalty. en-us Mon, 29 Nov 2021 00:00:00 +0530 Tue, 08 Feb 2022 06:53:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418062 Amounts received for WAN connectivity and bandwidth services were treated as non-taxable royalty because the customer obtained only a transmission and no possessory, operational, or treaty-covered right in the network, equipment, or process; the narrower India-UK DTAA definition prevailed over the wider domestic expansion. Amounts received for shrink-wrapped software were also held not to be royalty because the transaction involved a copyrighted article for end use, with no transfer of copyright rights or interest. On that reasoning, the disputed receipts could not be brought to tax in India as royalty. Case-Laws Income Tax Mon, 29 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418062