https://www.taxtmi.com/caselaws?id=310512 Licence fees received for transfer of user rights in software were examined as to whether they constituted royalty under Explanation 2 to Section 9(1)(vi) of the Income-tax Act and Article 12 of the India-Germany tax treaty, and whether amended Explanation 4 to Section 9(1)(vi) operated retrospectively from 1 June 1976. The Bombay HC admitted the appeal on substantial questions of law, but made no final adjudication on the merits of either issue. en-us Tue, 22 Jan 2013 00:00:00 +0530 Sat, 28 Oct 2023 13:13:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310512 Licence fees received for transfer of user rights in software were examined as to whether they constituted royalty under Explanation 2 to Section 9(1)(vi) of the Income-tax Act and Article 12 of the India-Germany tax treaty, and whether amended Explanation 4 to Section 9(1)(vi) operated retrospectively from 1 June 1976. The Bombay HC admitted the appeal on substantial questions of law, but made no final adjudication on the merits of either issue. Case-Laws Income Tax Tue, 22 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310512