https://www.taxtmi.com/highlights?id=92246 HC dismissed the revenue's appeal and affirmed the Tribunal's determination that income arising from the sale of software to a UK resident does not constitute "royalty" under the Income Tax Act or the India-UK DTAA. The court held that post-sale support services rendered by the respondent assessee did not effect a transfer of any right in the copyrighted article and therefore did not attract royalty characterization. The HC endorsed the Tribunal's application of the governing Supreme Court precedent, finding no substantial question of law warrants interference. Consequently, the taxpayer's software sale proceeds are not taxable as royalty in India. en-us Fri, 05 Sep 2025 08:10:37 +0530 Fri, 05 Sep 2025 08:10:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=92246 HC dismissed the revenue's appeal and affirmed the Tribunal's determination that income arising from the sale of software to a UK resident does not constitute "royalty" under the Income Tax Act or the India-UK DTAA. The court held that post-sale support services rendered by the respondent assessee did not effect a transfer of any right in the copyrighted article and therefore did not attract royalty characterization. The HC endorsed the Tribunal's application of the governing Supreme Court precedent, finding no substantial question of law warrants interference. Consequently, the taxpayer's software sale proceeds are not taxable as royalty in India. Highlights Income Tax Fri, 05 Sep 2025 08:10:37 +0530 https://www.taxtmi.com/highlights?id=92246