https://www.taxtmi.com/caselaws?id=444613 Receipts from resale of hardware and software packages by a mere distributor were not royalty because no right to use copyright was transferred; the Delhi ITAT applied Engineering Analysis and treated the income as sale of copyrighted articles, not royalty under the Act or the India-Singapore DTAA. Service charges were also not taxable as fee for technical services because, once the underlying receipts were not royalty, they could not be characterised as ancillary and subsidiary to royalty under Article 12(4)(a). The additions on both counts were deleted and the Revenue's appeals failed. en-us Tue, 25 Jul 2023 00:00:00 +0530 Thu, 19 Oct 2023 09:36:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444613 Receipts from resale of hardware and software packages by a mere distributor were not royalty because no right to use copyright was transferred; the Delhi ITAT applied Engineering Analysis and treated the income as sale of copyrighted articles, not royalty under the Act or the India-Singapore DTAA. Service charges were also not taxable as fee for technical services because, once the underlying receipts were not royalty, they could not be characterised as ancillary and subsidiary to royalty under Article 12(4)(a). The additions on both counts were deleted and the Revenue's appeals failed. Case-Laws Income Tax Tue, 25 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444613