https://www.taxtmi.com/caselaws?id=776202 Consideration for licensing of Customer Relationship Management (CRM) software was held not to qualify as royalty under the India Singapore DTAA; the ITAT's conclusion that such receipts are outside Article 12(3)'s royalty definition was affirmed, with the special leave petition dismissed by the Supreme Court, leaving the tax treatment in favour of the taxpayer (a Singapore resident) intact. The decision rests on treaty interpretation of licence receipts for software and confirms that the licensing structure at issue does not convert those receipts into taxable royalty income in India under the DTAA. en-us Fri, 01 Aug 2025 00:00:00 +0530 Mon, 09 Feb 2026 10:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776202 Consideration for licensing of Customer Relationship Management (CRM) software was held not to qualify as royalty under the India Singapore DTAA; the ITAT's conclusion that such receipts are outside Article 12(3)'s royalty definition was affirmed, with the special leave petition dismissed by the Supreme Court, leaving the tax treatment in favour of the taxpayer (a Singapore resident) intact. The decision rests on treaty interpretation of licence receipts for software and confirms that the licensing structure at issue does not convert those receipts into taxable royalty income in India under the DTAA. Case-Laws Income Tax Fri, 01 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776202