https://www.taxtmi.com/caselaws?id=755007 Payments to non-resident software suppliers under end-user licence or distribution arrangements do not create any interest in copyright and are not royalty under Section 9(1)(vi) of the Income-tax Act. Applying the Supreme Court ruling in Engineering Analysis Centre of Excellence (P.) Ltd., the Bombay HC treated such remittances as outside the royalty charge and held that tax deduction at source under Section 195 was not attracted where the DTAA definition was more beneficial. The revenue's contrary contention was no longer open, and the appeals raised no question of law. en-us Mon, 24 Jun 2024 00:00:00 +0530 Wed, 03 Jul 2024 16:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755007 Payments to non-resident software suppliers under end-user licence or distribution arrangements do not create any interest in copyright and are not royalty under Section 9(1)(vi) of the Income-tax Act. Applying the Supreme Court ruling in Engineering Analysis Centre of Excellence (P.) Ltd., the Bombay HC treated such remittances as outside the royalty charge and held that tax deduction at source under Section 195 was not attracted where the DTAA definition was more beneficial. The revenue's contrary contention was no longer open, and the appeals raised no question of law. Case-Laws Income Tax Mon, 24 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755007