https://www.taxtmi.com/caselaws?id=779628 Receipts from restrictive software licence and reseller arrangements were not taxable as fee for technical services because the assessee granted only a non-exclusive, non-transferable and non-sublicensable right, without transferring any proprietary interest or copyright. The technical-support element was merely ancillary and did not make available technical knowledge or skill to the Indian recipient, so the treaty definition of fee for technical services was not satisfied. The same principle was applied to treat the receipts as outside the royalty and FTS net under the Act and the India-USA DTAA. en-us Tue, 30 Sep 2025 00:00:00 +0530 Thu, 09 Oct 2025 08:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779628 Receipts from restrictive software licence and reseller arrangements were not taxable as fee for technical services because the assessee granted only a non-exclusive, non-transferable and non-sublicensable right, without transferring any proprietary interest or copyright. The technical-support element was merely ancillary and did not make available technical knowledge or skill to the Indian recipient, so the treaty definition of fee for technical services was not satisfied. The same principle was applied to treat the receipts as outside the royalty and FTS net under the Act and the India-USA DTAA. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779628