https://www.taxtmi.com/caselaws?id=762209 Receipts from software-related transactions and reseller arrangements were not taxable as fee for technical services because the agreements granted only a limited, non-exclusive, non-transferable and non-sublicensable licence, with no right to modify software or part with copyright. The support functions were ancillary and the record did not show rendering of technical service within the Act. The treaty "make available" condition was also not met, so the assessee's treatment of the income as not chargeable to tax was upheld. en-us Thu, 14 Nov 2024 00:00:00 +0530 Tue, 26 Nov 2024 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762209 Receipts from software-related transactions and reseller arrangements were not taxable as fee for technical services because the agreements granted only a limited, non-exclusive, non-transferable and non-sublicensable licence, with no right to modify software or part with copyright. The support functions were ancillary and the record did not show rendering of technical service within the Act. The treaty "make available" condition was also not met, so the assessee's treatment of the income as not chargeable to tax was upheld. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762209