https://www.taxtmi.com/caselaws?id=308524 Payments for the resale or use of computer software under licence or distribution arrangements were treated as not constituting royalty where the arrangement did not confer any right in copyright. Applying the Supreme Court's interpretation of the DTAA royalty article and section 9(1)(vi) of the Income-tax Act, the amounts paid to non-resident suppliers were therefore not taxable income in India. As no taxable income arose, the payer had no obligation to deduct tax at source under section 195. The question was answered in favour of the assessee, and the Revenue's appeal failed. en-us Fri, 03 Sep 2021 00:00:00 +0530 Fri, 30 Jun 2023 21:33:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308524 Payments for the resale or use of computer software under licence or distribution arrangements were treated as not constituting royalty where the arrangement did not confer any right in copyright. Applying the Supreme Court's interpretation of the DTAA royalty article and section 9(1)(vi) of the Income-tax Act, the amounts paid to non-resident suppliers were therefore not taxable income in India. As no taxable income arose, the payer had no obligation to deduct tax at source under section 195. The question was answered in favour of the assessee, and the Revenue's appeal failed. Case-Laws Income Tax Fri, 03 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308524