https://www.taxtmi.com/caselaws?id=309438 The High Court determined that income earned from distributing computer software in India does not qualify as royalty under Section 9(1)(vi) of the Act. The Court held that payments made by resident Indian distributors to non-resident software suppliers do not give rise to taxable income in India under the Double Taxation Avoidance Agreement. Additionally, the Court did not provide specific details on the chargeability of interest under Section 234B but indicated that the income classification decision would impact its applicability. The Court allowed the appeal and expedited related cases, offering clarity on the tax treatment of such transactions. en-us Mon, 18 Jul 2022 00:00:00 +0530 Sat, 02 Sep 2023 21:13:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309438 The High Court determined that income earned from distributing computer software in India does not qualify as royalty under Section 9(1)(vi) of the Act. The Court held that payments made by resident Indian distributors to non-resident software suppliers do not give rise to taxable income in India under the Double Taxation Avoidance Agreement. Additionally, the Court did not provide specific details on the chargeability of interest under Section 234B but indicated that the income classification decision would impact its applicability. The Court allowed the appeal and expedited related cases, offering clarity on the tax treatment of such transactions. Case-Laws Income Tax Mon, 18 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309438