https://www.taxtmi.com/caselaws?id=439858 Consideration for software supplied as an embedded part of telecom equipment was treated as business income rather than royalty because the licence granted use restrictions but did not transfer independent copyright rights. Offshore supply receipts were not attributed to the Indian permanent establishment because the contracts and payments were offshore, and only income arising from operations carried out in India can be allocated to a PE on a proper financial basis. Interest under section 234B was also held not chargeable to a non-resident where tax was subject to withholding at source. en-us Fri, 30 Jun 2023 00:00:00 +0530 Tue, 04 Jul 2023 08:57:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439858 Consideration for software supplied as an embedded part of telecom equipment was treated as business income rather than royalty because the licence granted use restrictions but did not transfer independent copyright rights. Offshore supply receipts were not attributed to the Indian permanent establishment because the contracts and payments were offshore, and only income arising from operations carried out in India can be allocated to a PE on a proper financial basis. Interest under section 234B was also held not chargeable to a non-resident where tax was subject to withholding at source. Case-Laws Income Tax Fri, 30 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439858