https://www.taxtmi.com/caselaws?id=437062 Software licence receipts were treated as business income rather than royalty because the arrangement did not transfer copyright rights; absent a permanent establishment in India, the income was not chargeable under the treaty. Related software implementation, enhancement, maintenance and consultancy receipts were not fees for technical services because the make available condition under the India-UK DTAA was not established and the services were integral to the software supply. Reimbursement receipts also were not taxable as fees for technical services where their reimbursement character was not displaced and no income element was shown. en-us Tue, 24 Jan 2023 00:00:00 +0530 Wed, 29 Jul 2026 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437062 Software licence receipts were treated as business income rather than royalty because the arrangement did not transfer copyright rights; absent a permanent establishment in India, the income was not chargeable under the treaty. Related software implementation, enhancement, maintenance and consultancy receipts were not fees for technical services because the make available condition under the India-UK DTAA was not established and the services were integral to the software supply. Reimbursement receipts also were not taxable as fees for technical services where their reimbursement character was not displaced and no income element was shown. Case-Laws Income Tax Tue, 24 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437062