https://www.taxtmi.com/caselaws?id=419444 The High Court dismissed the appeals challenging the taxation of software licensing as royalty under the Income Tax Act and relevant DTAA provisions. The Court held that payments made by Indian distributors to non-resident software suppliers do not constitute royalty, as there was no transfer of copyright involved in the licensing agreements. The decision emphasized the importance of specific agreements between parties in determining taxability and clarified that a mere grant of a license does not imply a transfer of copyright, thereby ruling out TDS liability under Section 195. en-us Mon, 07 Mar 2022 00:00:00 +0530 Thu, 30 Apr 2026 15:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=419444 The High Court dismissed the appeals challenging the taxation of software licensing as royalty under the Income Tax Act and relevant DTAA provisions. The Court held that payments made by Indian distributors to non-resident software suppliers do not constitute royalty, as there was no transfer of copyright involved in the licensing agreements. The decision emphasized the importance of specific agreements between parties in determining taxability and clarified that a mere grant of a license does not imply a transfer of copyright, thereby ruling out TDS liability under Section 195. Case-Laws Income Tax Mon, 07 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=419444