https://www.taxtmi.com/caselaws?id=35016 HC held that payments for imported shrink-wrapped computer software constituted royalty and were subject to tax withholding at source. The court ruled that charging provisions operate independently of TDS rules, and the tax authority need not determine the non-resident's taxable income before deducting tax; any payment yielding income to a non-resident attracts withholding. The decision followed earlier SC precedents affirming similar principles. en-us Thu, 24 Sep 2009 00:00:00 +0530 Wed, 20 Aug 2025 12:58:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35016 HC held that payments for imported shrink-wrapped computer software constituted royalty and were subject to tax withholding at source. The court ruled that charging provisions operate independently of TDS rules, and the tax authority need not determine the non-resident's taxable income before deducting tax; any payment yielding income to a non-resident attracts withholding. The decision followed earlier SC precedents affirming similar principles. Case-Laws Income Tax Thu, 24 Sep 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35016