https://www.taxtmi.com/caselaws?id=447968 Consideration received for sale or supply of off-the-shelf software was held not to constitute royalty under Article 12(3) of the Indo-Singapore Double Taxation Avoidance Agreement where no copyright in the software was transferred. The Tribunal's factual finding that the assessee had not transferred copyright, read with the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, led to the conclusion that such receipts could not be taxed as royalty. On that basis, the issue was decided in favour of the assessee and against the Revenue, and no substantial question of law arose. en-us Thu, 21 Dec 2023 00:00:00 +0530 Fri, 09 Jan 2026 17:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447968 Consideration received for sale or supply of off-the-shelf software was held not to constitute royalty under Article 12(3) of the Indo-Singapore Double Taxation Avoidance Agreement where no copyright in the software was transferred. The Tribunal's factual finding that the assessee had not transferred copyright, read with the Supreme Court ruling in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, led to the conclusion that such receipts could not be taxed as royalty. On that basis, the issue was decided in favour of the assessee and against the Revenue, and no substantial question of law arose. Case-Laws Income Tax Thu, 21 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447968