https://www.taxtmi.com/caselaws?id=426438 Software licence receipts from supply of standard software in object code form were treated as payments for a copyrighted article, not as consideration for any right to use copyright, process, or know-how. The Tribunal followed the Supreme Court in Engineering Analysis and held that, under the India-Singapore DTAA, such payments do not constitute royalty; the treaty definition prevailed over the wider domestic law position. On the same facts, related support-service receipts did not change that characterisation. The assessee's software-related receipts were therefore outside royalty taxation under the applicable treaty framework. en-us Wed, 03 Aug 2022 00:00:00 +0530 Thu, 09 Mar 2023 12:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426438 Software licence receipts from supply of standard software in object code form were treated as payments for a copyrighted article, not as consideration for any right to use copyright, process, or know-how. The Tribunal followed the Supreme Court in Engineering Analysis and held that, under the India-Singapore DTAA, such payments do not constitute royalty; the treaty definition prevailed over the wider domestic law position. On the same facts, related support-service receipts did not change that characterisation. The assessee's software-related receipts were therefore outside royalty taxation under the applicable treaty framework. Case-Laws Income Tax Wed, 03 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426438