https://www.taxtmi.com/caselaws?id=421986 Receipts from sale of Microsoft software products to Indian distributors were held to be consideration for a copyrighted article, not a transfer of copyright, and therefore did not constitute royalty under the India-USA DTAA or section 9(1)(vi) of the Income-tax Act. Receipts from cloud services were likewise held not to be royalty because subscribers obtained only online access, without any right to reproduce software or any transfer of rights in the underlying process, equipment, or infrastructure. The additions treating both streams as royalty were unsustainable in law. en-us Wed, 13 Apr 2022 00:00:00 +0530 Fri, 06 May 2022 08:30:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421986 Receipts from sale of Microsoft software products to Indian distributors were held to be consideration for a copyrighted article, not a transfer of copyright, and therefore did not constitute royalty under the India-USA DTAA or section 9(1)(vi) of the Income-tax Act. Receipts from cloud services were likewise held not to be royalty because subscribers obtained only online access, without any right to reproduce software or any transfer of rights in the underlying process, equipment, or infrastructure. The additions treating both streams as royalty were unsustainable in law. Case-Laws Income Tax Wed, 13 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421986