https://www.taxtmi.com/caselaws?id=421300 Receipts from software licensing or resale are not royalty where the customer acquires only a copyrighted article and no copyright rights are transferred. Applying that settled principle, the software receipts were held not taxable as royalty. Cloud subscription receipts were also not royalty because customers merely accessed online services without any right to reproduce, possess, or control the underlying software or infrastructure, and no use-right in equipment or copyright was conferred. The royalty-based additions were therefore unsustainable, and the assessment was set aside. en-us Wed, 13 Apr 2022 00:00:00 +0530 Wed, 20 Apr 2022 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421300 Receipts from software licensing or resale are not royalty where the customer acquires only a copyrighted article and no copyright rights are transferred. Applying that settled principle, the software receipts were held not taxable as royalty. Cloud subscription receipts were also not royalty because customers merely accessed online services without any right to reproduce, possess, or control the underlying software or infrastructure, and no use-right in equipment or copyright was conferred. The royalty-based additions were therefore unsustainable, and the assessment was set aside. Case-Laws Income Tax Wed, 13 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421300