https://www.taxtmi.com/caselaws?id=308496 Payments made for computer software under distribution or end-user licence arrangements were treated as outside the scope of royalty because the Supreme Court in Engineering Analysis held that such consideration for resale or use of software does not amount to payment for use of copyright. Applying that ruling, the Madras HC held that section 9(1)(vi) did not apply on the facts, so no income was chargeable in India from the software payments and no obligation to deduct tax at source arose under section 195. The issue was therefore decided in favour of the assessee and against the Revenue. en-us Mon, 20 Dec 2021 00:00:00 +0530 Thu, 29 Jun 2023 20:58:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308496 Payments made for computer software under distribution or end-user licence arrangements were treated as outside the scope of royalty because the Supreme Court in Engineering Analysis held that such consideration for resale or use of software does not amount to payment for use of copyright. Applying that ruling, the Madras HC held that section 9(1)(vi) did not apply on the facts, so no income was chargeable in India from the software payments and no obligation to deduct tax at source arose under section 195. The issue was therefore decided in favour of the assessee and against the Revenue. Case-Laws Income Tax Mon, 20 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308496