https://www.taxtmi.com/caselaws?id=447759 Receipts from sale and distribution of software were held to be outside royalty and fee for technical services taxation where the agreements showed only a limited right to use copyrighted articles, with no transfer of copyright or source code. The revenue's reliance on selected contractual clauses was rejected because the arrangements, read as a whole, involved distribution of software products rather than transfer of any copyright interest. The facts were found to fall within Engineering Analysis, and the addition made on the royalty basis was unsustainable. en-us Tue, 02 Jan 2024 00:00:00 +0530 Thu, 04 Jan 2024 06:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447759 Receipts from sale and distribution of software were held to be outside royalty and fee for technical services taxation where the agreements showed only a limited right to use copyrighted articles, with no transfer of copyright or source code. The revenue's reliance on selected contractual clauses was rejected because the arrangements, read as a whole, involved distribution of software products rather than transfer of any copyright interest. The facts were found to fall within Engineering Analysis, and the addition made on the royalty basis was unsustainable. Case-Laws Income Tax Tue, 02 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447759