https://www.taxtmi.com/caselaws?id=462129 Amounts paid for software subscription and access to cloud-based software were held not to constitute royalty because the arrangement conferred only a right to use the software, not any transfer of copyright or interest in the underlying intellectual property. On that basis, the income was not taxable in India as royalty and the payer had no obligation to deduct tax at source under section 195. The same reasoning was applied to cloud-based software access, which was also found not to amount to use of industrial, commercial or scientific equipment, or to managerial, technical or consultancy services within the royalty framework. en-us Tue, 02 Jul 2024 00:00:00 +0530 Tue, 27 May 2025 10:22:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462129 Amounts paid for software subscription and access to cloud-based software were held not to constitute royalty because the arrangement conferred only a right to use the software, not any transfer of copyright or interest in the underlying intellectual property. On that basis, the income was not taxable in India as royalty and the payer had no obligation to deduct tax at source under section 195. The same reasoning was applied to cloud-based software access, which was also found not to amount to use of industrial, commercial or scientific equipment, or to managerial, technical or consultancy services within the royalty framework. Case-Laws Income Tax Tue, 02 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462129