https://www.taxtmi.com/caselaws?id=754733 Consideration for a non-exclusive, non-transferable and non-sublicensable licence to use software, where no copyright rights are transferred, is not royalty under the treaty. Ancillary maintenance receipts connected with support, bug fixing and technical assistance also do not become fees for included services merely because they accompany the software supply, and the make available test was not satisfied. The additions were deleted and the assessee succeeded. en-us Mon, 08 Jan 2024 00:00:00 +0530 Sat, 29 Jun 2024 08:09:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754733 Consideration for a non-exclusive, non-transferable and non-sublicensable licence to use software, where no copyright rights are transferred, is not royalty under the treaty. Ancillary maintenance receipts connected with support, bug fixing and technical assistance also do not become fees for included services merely because they accompany the software supply, and the make available test was not satisfied. The additions were deleted and the assessee succeeded. Case-Laws Income Tax Mon, 08 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754733