https://www.taxtmi.com/caselaws?id=435092 Software licence reimbursement payments for shrink-wrap software on a non-exclusive, non-transferable basis were not royalty because the parent entity merely facilitated use of licences held in its name and no right in copyright was parted with. Applying Engineering Analysis Centre of Excellence Private Limited, the ITAT held that such payments are not consideration for the use of, or right to use, copyright and therefore do not create a tax deduction obligation under section 195 where no taxable royalty income exists. The consequential demand, addition and interest were deleted in favour of the assessee. en-us Tue, 07 Mar 2023 00:00:00 +0530 Sat, 11 Mar 2023 08:49:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435092 Software licence reimbursement payments for shrink-wrap software on a non-exclusive, non-transferable basis were not royalty because the parent entity merely facilitated use of licences held in its name and no right in copyright was parted with. Applying Engineering Analysis Centre of Excellence Private Limited, the ITAT held that such payments are not consideration for the use of, or right to use, copyright and therefore do not create a tax deduction obligation under section 195 where no taxable royalty income exists. The consequential demand, addition and interest were deleted in favour of the assessee. Case-Laws Income Tax Tue, 07 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435092