https://www.taxtmi.com/caselaws?id=418263 Receipts from integrated supply of hardware with embedded software, related support and reimbursement amounts were examined for characterisation as royalty or fees for technical services under the Act and the India-United Kingdom DTAA. The text notes that embedded software in an integrated product may be treated as a transfer of a copyrighted article rather than copyright rights, that treaty-based FTS depends on satisfaction of the make available test, and that pure cost-to-cost reimbursements are not income if properly supported by expenditure records. It also states that, for a non-resident where tax was deductible at source, interest under section 234B is not leviable. en-us Tue, 28 Dec 2021 00:00:00 +0530 Tue, 15 Feb 2022 17:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418263 Receipts from integrated supply of hardware with embedded software, related support and reimbursement amounts were examined for characterisation as royalty or fees for technical services under the Act and the India-United Kingdom DTAA. The text notes that embedded software in an integrated product may be treated as a transfer of a copyrighted article rather than copyright rights, that treaty-based FTS depends on satisfaction of the make available test, and that pure cost-to-cost reimbursements are not income if properly supported by expenditure records. It also states that, for a non-resident where tax was deductible at source, interest under section 234B is not leviable. Case-Laws Income Tax Tue, 28 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418263