https://www.taxtmi.com/caselaws?id=30030 A non-exclusive, non-transferable licence to use copyrighted software and accompanying documentation was treated as royalty because the recipient obtained only use rights while copyright remained with the supplier; the linked consideration was therefore taxable in India. Installation, testing and training services were held to be technical in character and ancillary to the software licence, so they were taxable as fees for technical services or included services. Hardware supplied under the same arrangement was treated as an outright sale, and absent a permanent establishment in India, the related business profits were not taxable in India. en-us Mon, 28 Jul 2008 00:00:00 +0530 Tue, 09 Sep 2008 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=30030 A non-exclusive, non-transferable licence to use copyrighted software and accompanying documentation was treated as royalty because the recipient obtained only use rights while copyright remained with the supplier; the linked consideration was therefore taxable in India. Installation, testing and training services were held to be technical in character and ancillary to the software licence, so they were taxable as fees for technical services or included services. Hardware supplied under the same arrangement was treated as an outright sale, and absent a permanent establishment in India, the related business profits were not taxable in India. Case-Laws Income Tax Mon, 28 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=30030