https://www.taxtmi.com/caselaws?id=421003 Consideration from sale of software to Indian resellers and distributors was held not to be royalty under section 9(1)(vi) or Article 12 of the India-USA DTAA because the arrangements only allowed resale of software products and did not transfer any right in copyright or any right to use copyright. Applying its earlier year decision and the Supreme Court ruling on computer software distributions, the Tribunal treated the receipts as business sale proceeds rather than royalty, with the result that the Revenue's royalty characterisation failed. en-us Thu, 31 Mar 2022 00:00:00 +0530 Wed, 13 Apr 2022 18:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421003 Consideration from sale of software to Indian resellers and distributors was held not to be royalty under section 9(1)(vi) or Article 12 of the India-USA DTAA because the arrangements only allowed resale of software products and did not transfer any right in copyright or any right to use copyright. Applying its earlier year decision and the Supreme Court ruling on computer software distributions, the Tribunal treated the receipts as business sale proceeds rather than royalty, with the result that the Revenue's royalty characterisation failed. Case-Laws Income Tax Thu, 31 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421003