https://www.taxtmi.com/caselaws?id=313072 Receipts from a non-transferable, non-exclusive software licence and related hardware were held not to be royalty because the arrangement granted only use of a copyrighted article without transferring any copyright or proprietary interest. The Tribunal also held that routine maintenance and support services were not fees for technical services, as they did not make available technical knowledge, skill, experience, know-how, or technical design to the customers and failed the treaty make available test under the India-United Kingdom DTAA. Applying its earlier view in the assessee's own case, it deleted the additions on both issues. en-us Wed, 13 Dec 2023 00:00:00 +0530 Fri, 22 Mar 2024 06:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313072 Receipts from a non-transferable, non-exclusive software licence and related hardware were held not to be royalty because the arrangement granted only use of a copyrighted article without transferring any copyright or proprietary interest. The Tribunal also held that routine maintenance and support services were not fees for technical services, as they did not make available technical knowledge, skill, experience, know-how, or technical design to the customers and failed the treaty make available test under the India-United Kingdom DTAA. Applying its earlier view in the assessee's own case, it deleted the additions on both issues. Case-Laws Income Tax Wed, 13 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313072