https://www.taxtmi.com/forum/issue?id=120064 The one time payment for a customized software that grants only non exclusive internal user rights without transfer of copyright does not constitute taxable income in India and need not attract Tax Deduction at Source. Annual subscription fees may be taxable depending on whether they confer mere access or include technical support/customization; absence of treaty documentation or bundled services may convert subscription receipts into taxable royalty or fees for technical services, requiring withholding. Payers should verify contractual rights, obtain residency and corroborative documents, and consider obtaining a withholding certificate if ambiguous. en-us Wed, 28 May 2025 09:31:23 +0530 Mon, 02 Jun 2025 18:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=120064 The one time payment for a customized software that grants only non exclusive internal user rights without transfer of copyright does not constitute taxable income in India and need not attract Tax Deduction at Source. Annual subscription fees may be taxable depending on whether they confer mere access or include technical support/customization; absence of treaty documentation or bundled services may convert subscription receipts into taxable royalty or fees for technical services, requiring withholding. Payers should verify contractual rights, obtain residency and corroborative documents, and consider obtaining a withholding certificate if ambiguous. Discussion-Forum Income Tax Wed, 28 May 2025 09:31:23 +0530 https://www.taxtmi.com/forum/issue?id=120064