https://www.taxtmi.com/caselaws?id=778256 Supply of standard software, together with incidental support and maintenance services, was treated as consideration for use of a copyrighted article rather than royalty where no copyright was transferred, the supplier retained intellectual property rights, and the customer received only a revocable, non-exclusive and non-transferable licence; the receipts were therefore outside section 9(1)(vi) and Article 12 of the India-Ireland DTAA. The alleged refund required factual verification, and tax liability was to be recomputed if the refund had not in fact been granted. The challenge to initiation of penalty proceedings was premature because no concluded penalty order was under appeal. en-us Thu, 04 Sep 2025 00:00:00 +0530 Fri, 12 Sep 2025 08:47:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778256 Supply of standard software, together with incidental support and maintenance services, was treated as consideration for use of a copyrighted article rather than royalty where no copyright was transferred, the supplier retained intellectual property rights, and the customer received only a revocable, non-exclusive and non-transferable licence; the receipts were therefore outside section 9(1)(vi) and Article 12 of the India-Ireland DTAA. The alleged refund required factual verification, and tax liability was to be recomputed if the refund had not in fact been granted. The challenge to initiation of penalty proceedings was premature because no concluded penalty order was under appeal. Case-Laws Income Tax Thu, 04 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778256