https://www.taxtmi.com/caselaws?id=435524 The Tribunal held that the amount received from the sale of software is not royalty under the India-USA Double Taxation Avoidance Agreement. The decision was based on the clarification that consideration for the sale of copyrighted software does not constitute royalty. The Tribunal overruled the Commissioner (Appeals) and directed the Assessing Officer to delete the addition, following the Supreme Court and Jurisdictional High Court's decisions. 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 The Tribunal held that the amount received from the sale of software is not royalty under the India-USA Double Taxation Avoidance Agreement. The decision was based on the clarification that consideration for the sale of copyrighted software does not constitute royalty. The Tribunal overruled the Commissioner (Appeals) and directed the Assessing Officer to delete the addition, following the Supreme Court and Jurisdictional High Court's decisions. Case-Laws Income Tax Fri, 17 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435524