https://www.taxtmi.com/caselaws?id=755292 Payments made by Indian end-users or distributors to non-resident software suppliers under distribution agreements or end-user licence agreements do not constitute royalty under Section 9(1)(vi) where no copyright is transferred and only limited use of software is permitted. Following Engineering Analysis Centre of Excellence (P.) Ltd., such consideration is not taxable in India as royalty, and the existence of a DTAA reinforces that position. The issue was therefore decided against the Revenue and in favour of the assessee. en-us Tue, 02 Jul 2024 00:00:00 +0530 Wed, 10 Jul 2024 08:02:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755292 Payments made by Indian end-users or distributors to non-resident software suppliers under distribution agreements or end-user licence agreements do not constitute royalty under Section 9(1)(vi) where no copyright is transferred and only limited use of software is permitted. Following Engineering Analysis Centre of Excellence (P.) Ltd., such consideration is not taxable in India as royalty, and the existence of a DTAA reinforces that position. The issue was therefore decided against the Revenue and in favour of the assessee. Case-Laws Income Tax Tue, 02 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755292