https://www.taxtmi.com/caselaws?id=777415 Amounts received for a limited end-user software licence were not taxable as royalty under Article 12(3) of the India-USA DTAA because the agreements granted only a non-transferable right to use object code software. No copyright, title, proprietary interest, or source code access passed to the licensees, and restrictions on copying, sublicensing, reverse engineering, decompiling, and disassembling confirmed that no rights in the copyrighted work were transferred. Consideration for such a restricted licence therefore did not constitute royalty under the treaty, and the Revenue's challenge failed. en-us Mon, 25 Aug 2025 00:00:00 +0530 Fri, 29 Aug 2025 08:56:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777415 Amounts received for a limited end-user software licence were not taxable as royalty under Article 12(3) of the India-USA DTAA because the agreements granted only a non-transferable right to use object code software. No copyright, title, proprietary interest, or source code access passed to the licensees, and restrictions on copying, sublicensing, reverse engineering, decompiling, and disassembling confirmed that no rights in the copyrighted work were transferred. Consideration for such a restricted licence therefore did not constitute royalty under the treaty, and the Revenue's challenge failed. Case-Laws Income Tax Mon, 25 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777415