https://www.taxtmi.com/caselaws?id=751025 Payment for computer software under a non-exclusive licence or EULA was treated as not transferring copyright, and the tax issue concerned whether such payments constitute royalty under section 9(1)(vi) of the Income Tax Act read with Article 12 of the Indo-US DTAA. The Supreme Court noted that the issues had already been answered by the three-judge Bench decision in Engineering Analysis Centre of Excellence Pvt. Ltd. and, following that ruling and the order in M/s Gracemac Corporation, dismissed the special leave petition on merits as well as for delay. en-us Mon, 01 Apr 2024 00:00:00 +0530 Fri, 08 May 2026 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751025 Payment for computer software under a non-exclusive licence or EULA was treated as not transferring copyright, and the tax issue concerned whether such payments constitute royalty under section 9(1)(vi) of the Income Tax Act read with Article 12 of the Indo-US DTAA. The Supreme Court noted that the issues had already been answered by the three-judge Bench decision in Engineering Analysis Centre of Excellence Pvt. Ltd. and, following that ruling and the order in M/s Gracemac Corporation, dismissed the special leave petition on merits as well as for delay. Case-Laws Income Tax Mon, 01 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751025