https://www.taxtmi.com/highlights?id=83412 The case revolves around the taxation of income earned by the assessee from licensing software to Indian customers under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The assessee provided the right to use computer software licenses through End User License Agreements (EULAs) or reseller agreements to Indian customers. It contended that such income was not taxable u/s 9(1)(vii) of the Income Tax Act or Article 12 (Royalty) of the India-USA DTAA. The ITAT held that the assessee's reliance on the Supreme Court decision in Engineering Analysis Centre of Excellence Pvt. Ltd. was well-founded. The transaction fell under the second category of software sale, granting non-exclusive restrictive licenses, which would ..... en-us Wed, 27 Nov 2024 08:58:24 +0530 Wed, 27 Nov 2024 08:58:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=83412 The case revolves around the taxation of income earned by the assessee from licensing software to Indian customers under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The assessee provided the right to use computer software licenses through End User License Agreements (EULAs) or reseller agreements to Indian customers. It contended that such income was not taxable u/s 9(1)(vii) of the Income Tax Act or Article 12 (Royalty) of the India-USA DTAA. The ITAT held that the assessee's reliance on the Supreme Court decision in Engineering Analysis Centre of Excellence Pvt. Ltd. was well-founded. The transaction fell under the second category of software sale, granting non-exclusive restrictive licenses, which would ..... Highlights Income Tax Wed, 27 Nov 2024 08:58:24 +0530 https://www.taxtmi.com/highlights?id=83412