https://www.taxtmi.com/caselaws?id=301266 Payments to non-resident dealers for reimbursement of warranty expenses were held to relate to income from sources outside India and thus fall within the exclusion under the deeming provision, so no tax was required to be deducted at source. Payments for licensed software were characterised as purchase of a copyrighted article and limited-use licence rights, not transfer or use of copyright; consequently such payments are business income, not royalty or fees for technical services, and no TDS arose. Corresponding interest liability under the secondary recovery provision was deleted as the primary TDS obligations did not arise. en-us Wed, 21 Mar 2018 00:00:00 +0530 Tue, 20 Jan 2026 17:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301266 Payments to non-resident dealers for reimbursement of warranty expenses were held to relate to income from sources outside India and thus fall within the exclusion under the deeming provision, so no tax was required to be deducted at source. Payments for licensed software were characterised as purchase of a copyrighted article and limited-use licence rights, not transfer or use of copyright; consequently such payments are business income, not royalty or fees for technical services, and no TDS arose. Corresponding interest liability under the secondary recovery provision was deleted as the primary TDS obligations did not arise. Case-Laws Income Tax Wed, 21 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301266