https://www.taxtmi.com/caselaws?id=308047 Consideration paid to non-resident suppliers for software under end-user licence or distribution agreements was treated as payment for a copyrighted article, not for any right in copyright. Applying Engineering Analysis, such non-exclusive licences do not create royalty income, the treaty position prevails where more beneficial, and no income chargeable to tax arose in India from these receipts. As a result, the payer had no obligation to deduct tax at source under section 195, and the appeals were dismissed. en-us Fri, 05 Aug 2022 00:00:00 +0530 Tue, 27 Jun 2023 13:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308047 Consideration paid to non-resident suppliers for software under end-user licence or distribution agreements was treated as payment for a copyrighted article, not for any right in copyright. Applying Engineering Analysis, such non-exclusive licences do not create royalty income, the treaty position prevails where more beneficial, and no income chargeable to tax arose in India from these receipts. As a result, the payer had no obligation to deduct tax at source under section 195, and the appeals were dismissed. Case-Laws Income Tax Fri, 05 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308047