https://www.taxtmi.com/caselaws?id=752694 Royalty characterization of software licensing and cloud subscription receipts remains the central issue, with the Tribunal treating neither software sale/licensing income nor cloud service subscription fees as royalty. The Revenue contended that the dispute is covered by Engineering Analysis Centre of Excellence (P.) Ltd., while a review petition on that ruling is stated to be pending. The Delhi High Court closed the appeal for want of a substantial question of law, and the Special Leave Petition was later dismissed as time-barred because the delay was not satisfactorily explained. en-us Mon, 06 May 2024 00:00:00 +0530 Thu, 16 May 2024 09:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752694 Royalty characterization of software licensing and cloud subscription receipts remains the central issue, with the Tribunal treating neither software sale/licensing income nor cloud service subscription fees as royalty. The Revenue contended that the dispute is covered by Engineering Analysis Centre of Excellence (P.) Ltd., while a review petition on that ruling is stated to be pending. The Delhi High Court closed the appeal for want of a substantial question of law, and the Special Leave Petition was later dismissed as time-barred because the delay was not satisfactorily explained. Case-Laws Income Tax Mon, 06 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752694