https://www.taxtmi.com/caselaws?id=307838 Payments for software licences or end-user download arrangements to non-resident vendors were not royalty because they did not involve transfer of any right in copyright under Section 9(1)(vi) or the applicable DTAA. Applying Engineering Analysis, the court held that no income was chargeable to tax in India on that basis, so tax deduction at source under Section 195 was not required. The assessee therefore could not be treated as an assessee in default under Section 201(1). en-us Tue, 03 Aug 2021 00:00:00 +0530 Thu, 11 May 2023 16:45:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307838 Payments for software licences or end-user download arrangements to non-resident vendors were not royalty because they did not involve transfer of any right in copyright under Section 9(1)(vi) or the applicable DTAA. Applying Engineering Analysis, the court held that no income was chargeable to tax in India on that basis, so tax deduction at source under Section 195 was not required. The assessee therefore could not be treated as an assessee in default under Section 201(1). Case-Laws Income Tax Tue, 03 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307838