https://www.taxtmi.com/caselaws?id=308997 Income from licensing or sale of software products and subscription receipts for cloud services was treated as not taxable as royalty under Section 9(1)(vi) of the Income-tax Act, 1961 and the applicable treaty provisions. The Delhi HC applied the Supreme Court's ruling in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, which held that consideration for software transactions is not royalty, and extended the same approach to cloud-service subscription receipts. On that basis, no substantial question of law survived, and the issue was decided in favour of the assessee. en-us Thu, 16 Feb 2023 00:00:00 +0530 Fri, 04 Aug 2023 21:24:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308997 Income from licensing or sale of software products and subscription receipts for cloud services was treated as not taxable as royalty under Section 9(1)(vi) of the Income-tax Act, 1961 and the applicable treaty provisions. The Delhi HC applied the Supreme Court's ruling in Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT, which held that consideration for software transactions is not royalty, and extended the same approach to cloud-service subscription receipts. On that basis, no substantial question of law survived, and the issue was decided in favour of the assessee. Case-Laws Income Tax Thu, 16 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308997