https://www.taxtmi.com/caselaws?id=755749 The Bombay HC ruled in favor of the assessee regarding royalty receipts from software supply. The revenue contended that payments received from Reliance for copyright software under a Wireless Software Assignment and License Agreement constituted taxable royalty income in India. The assessee argued it was business income not taxable in India absent a Permanent Establishment. The HC held that following precedents from Commissioner of Income Tax v. Reliance Industries Ltd. and Engineering Analysis Centre of Excellence, remittances for computer software purchases are not liable to tax as royalty under Section 9(1)(vi), rejecting the Assessing Officer's approach as legally incorrect. en-us Mon, 01 Jul 2024 00:00:00 +0530 Wed, 17 Jul 2024 10:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755749 The Bombay HC ruled in favor of the assessee regarding royalty receipts from software supply. The revenue contended that payments received from Reliance for copyright software under a Wireless Software Assignment and License Agreement constituted taxable royalty income in India. The assessee argued it was business income not taxable in India absent a Permanent Establishment. The HC held that following precedents from Commissioner of Income Tax v. Reliance Industries Ltd. and Engineering Analysis Centre of Excellence, remittances for computer software purchases are not liable to tax as royalty under Section 9(1)(vi), rejecting the Assessing Officer's approach as legally incorrect. Case-Laws Income Tax Mon, 01 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755749