https://www.taxtmi.com/caselaws?id=446295 Consideration for off-the-shelf software was held not to be royalty where the arrangement involved only a licence or resale right and no transfer of copyright, so the covered software receipts were not taxable as royalty. Receipts from telecom bandwidth facility were also held outside royalty, because the treaty definition was not automatically enlarged by domestic law amendments, and the bandwidth charges did not fall within the applicable treaty provision. Information technology support services were likewise not taxable as fees for technical services, as they did not make available technical knowledge, experience or skill, and no royalty character was established. The disputed additions were therefore deleted on the principal issues, with only a limited concession for two entities left undisturbed. en-us Tue, 10 Oct 2023 00:00:00 +0530 Fri, 15 Dec 2023 12:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446295 Consideration for off-the-shelf software was held not to be royalty where the arrangement involved only a licence or resale right and no transfer of copyright, so the covered software receipts were not taxable as royalty. Receipts from telecom bandwidth facility were also held outside royalty, because the treaty definition was not automatically enlarged by domestic law amendments, and the bandwidth charges did not fall within the applicable treaty provision. Information technology support services were likewise not taxable as fees for technical services, as they did not make available technical knowledge, experience or skill, and no royalty character was established. The disputed additions were therefore deleted on the principal issues, with only a limited concession for two entities left undisturbed. Case-Laws Income Tax Tue, 10 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446295