https://www.taxtmi.com/caselaws?id=306809 Consideration for supply and distribution of copyrighted software products was treated as payment for sale of a copyrighted article, not for transfer of copyright rights. On that legal distinction, the receipts were not taxable as royalty under Article 12 of the India-Ireland DTAA or under section 9(1)(vi) of the Income-tax Act. The analysis also noted that the same issue had already been resolved in the assessee's favour for an earlier year by applying jurisdictional High Court rulings. Because the treaty position was more beneficial, the domestic deeming provision did not require separate examination. en-us Thu, 09 Jul 2020 00:00:00 +0530 Sun, 26 Feb 2023 09:22:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306809 Consideration for supply and distribution of copyrighted software products was treated as payment for sale of a copyrighted article, not for transfer of copyright rights. On that legal distinction, the receipts were not taxable as royalty under Article 12 of the India-Ireland DTAA or under section 9(1)(vi) of the Income-tax Act. The analysis also noted that the same issue had already been resolved in the assessee's favour for an earlier year by applying jurisdictional High Court rulings. Because the treaty position was more beneficial, the domestic deeming provision did not require separate examination. Case-Laws Income Tax Thu, 09 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306809