https://www.taxtmi.com/caselaws?id=435524 Consideration received from sale of software to Indian customers was not royalty under Article 12(3) of the India-USA DTAA because the software was sold as a copyrighted article for internal use, with no transfer of copyright or any right to use copyright. Applying Engineering Analysis Centre of Excellence Pvt. Ltd., the payment was treated as sale proceeds for the software product itself, not for use of a literary work or process, and the addition was deleted. en-us Fri, 17 Feb 2023 00:00:00 +0530 Tue, 21 Mar 2023 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435524 Consideration received from sale of software to Indian customers was not royalty under Article 12(3) of the India-USA DTAA because the software was sold as a copyrighted article for internal use, with no transfer of copyright or any right to use copyright. Applying Engineering Analysis Centre of Excellence Pvt. Ltd., the payment was treated as sale proceeds for the software product itself, not for use of a literary work or process, and the addition was deleted. Case-Laws Income Tax Fri, 17 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435524