https://www.taxtmi.com/caselaws?id=447290 ITAT Delhi held that payments received by assessee from Indian entity for providing facilities to Volvo Indian entities did not constitute royalty taxable at 10% of gross receipts. The assessee argued that Indian entities did not obtain rights to use copyright in software/business applications. Following Delhi HC judgment in EY Global Services Ltd. and SC precedent in Engineering Analysis Centre of Excellence, ITAT ruled that payments for providing access to computer software do not amount to royalty under Income Tax Act, 1961 and India-UK DTAA. Appeal allowed. en-us Wed, 20 Dec 2023 00:00:00 +0530 Thu, 21 Dec 2023 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447290 ITAT Delhi held that payments received by assessee from Indian entity for providing facilities to Volvo Indian entities did not constitute royalty taxable at 10% of gross receipts. The assessee argued that Indian entities did not obtain rights to use copyright in software/business applications. Following Delhi HC judgment in EY Global Services Ltd. and SC precedent in Engineering Analysis Centre of Excellence, ITAT ruled that payments for providing access to computer software do not amount to royalty under Income Tax Act, 1961 and India-UK DTAA. Appeal allowed. Case-Laws Income Tax Wed, 20 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447290