https://www.taxtmi.com/caselaws?id=779305 Gross delay in filing the Special Leave Petitions was not condoned because the reasons offered were found neither satisfactory nor sufficient in law, so the condonation applications were dismissed. On merits, the Court followed Engineering Analysis and held that distribution agreements/EULAs in these cases did not grant any interest or right in copyright amounting to use or right to use copyright; accordingly, the interconnect service charges were not royalty and there was no obligation under section 195 to deduct tax at source. The royalty provisions in section 9(1)(vi) and its explanations 2 and 4 were held inapplicable on these facts, and the SLPs were dismissed. en-us Fri, 26 Sep 2025 00:00:00 +0530 Fri, 03 Oct 2025 08:30:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779305 Gross delay in filing the Special Leave Petitions was not condoned because the reasons offered were found neither satisfactory nor sufficient in law, so the condonation applications were dismissed. On merits, the Court followed Engineering Analysis and held that distribution agreements/EULAs in these cases did not grant any interest or right in copyright amounting to use or right to use copyright; accordingly, the interconnect service charges were not royalty and there was no obligation under section 195 to deduct tax at source. The royalty provisions in section 9(1)(vi) and its explanations 2 and 4 were held inapplicable on these facts, and the SLPs were dismissed. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779305