https://www.taxtmi.com/caselaws?id=308989 Receipts from software sales and cloud-service subscriptions were held not to constitute royalty, following binding precedent in the assessee's own earlier years. The Tribunal applied the principle that sale of software as a copyrighted article does not involve transfer of copyright rights, and that mere online access to cloud services, without any right to use, reproduce, or exploit the underlying software or infrastructure, is likewise outside the scope of royalty. The Revenue's treatment of both receipts as royalty was rejected and the addition was deleted. en-us Wed, 31 Aug 2022 00:00:00 +0530 Fri, 04 Aug 2023 21:24:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308989 Receipts from software sales and cloud-service subscriptions were held not to constitute royalty, following binding precedent in the assessee's own earlier years. The Tribunal applied the principle that sale of software as a copyrighted article does not involve transfer of copyright rights, and that mere online access to cloud services, without any right to use, reproduce, or exploit the underlying software or infrastructure, is likewise outside the scope of royalty. The Revenue's treatment of both receipts as royalty was rejected and the addition was deleted. Case-Laws Income Tax Wed, 31 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308989