https://www.taxtmi.com/caselaws?id=300551 Supply of software under distribution or embedded-hardware arrangements does not, by itself, confer any right in copyright and therefore is not royalty under section 9(1)(vi) of the Income-tax Act or Article 13(3) of the India-France DTAA. The commentary applies the principle affirmed in Ericsson and Engineering Analysis, and notes that retrospective Explanations to section 9(1)(vi) do not alter that result. On that basis, receipts from software supply were treated as outside the royalty charge in India. en-us Thu, 30 Sep 2021 00:00:00 +0530 Fri, 11 Feb 2022 07:18:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300551 Supply of software under distribution or embedded-hardware arrangements does not, by itself, confer any right in copyright and therefore is not royalty under section 9(1)(vi) of the Income-tax Act or Article 13(3) of the India-France DTAA. The commentary applies the principle affirmed in Ericsson and Engineering Analysis, and notes that retrospective Explanations to section 9(1)(vi) do not alter that result. On that basis, receipts from software supply were treated as outside the royalty charge in India. Case-Laws Income Tax Thu, 30 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300551