https://www.taxtmi.com/caselaws?id=751410 ITAT Bangalore held that sale proceeds from software licenses to associated enterprises and Indian customers cannot be categorized as royalty under DTAA provisions. Following SC precedent in Engineering Analysis Centre of Excellence Pvt. Ltd. and assessee's own case from Karnataka HC, the tribunal set aside CIT(A)'s order and directed AO to delete the addition made as royalty income. Decision favored assessee. en-us Wed, 27 Mar 2024 00:00:00 +0530 Tue, 16 Apr 2024 07:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751410 ITAT Bangalore held that sale proceeds from software licenses to associated enterprises and Indian customers cannot be categorized as royalty under DTAA provisions. Following SC precedent in Engineering Analysis Centre of Excellence Pvt. Ltd. and assessee's own case from Karnataka HC, the tribunal set aside CIT(A)'s order and directed AO to delete the addition made as royalty income. Decision favored assessee. Case-Laws Income Tax Wed, 27 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751410