https://www.taxtmi.com/caselaws?id=752433 Receipts from software supply and related maintenance services were held not taxable as royalty where the agreements granted only a limited, non-exclusive, non-transferable licence to use the software, with no transfer of copyright or right to reproduce the programme. The Tribunal applied the principle that consideration for a copyrighted article, as distinct from consideration for copyright rights, does not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 13 of the India-UK treaty. It also followed the earlier year's identical factual and legal determination and treated the software-related receipts as outside royalty taxation on the facts before it. en-us Tue, 07 May 2024 00:00:00 +0530 Fri, 10 May 2024 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752433 Receipts from software supply and related maintenance services were held not taxable as royalty where the agreements granted only a limited, non-exclusive, non-transferable licence to use the software, with no transfer of copyright or right to reproduce the programme. The Tribunal applied the principle that consideration for a copyrighted article, as distinct from consideration for copyright rights, does not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 13 of the India-UK treaty. It also followed the earlier year's identical factual and legal determination and treated the software-related receipts as outside royalty taxation on the facts before it. Case-Laws Income Tax Tue, 07 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752433