https://www.taxtmi.com/caselaws?id=784485 Adequate opportunity was found to have been given before the DRP, so the natural justice objection failed, and past treatment in earlier years did not bind the Revenue because there is no res judicata in income-tax proceedings. On the substantive tax issue, receipts from software-linked maintenance support, education and training services were held not taxable as fees for technical services because they were intrinsically connected with the software licences and the Revenue failed to establish the treaty's make available condition. The related service receipts were therefore deleted, and the software licence receipts were not sustained as royalty on the same linked-transaction reasoning. en-us Tue, 30 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 16:11:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784485 Adequate opportunity was found to have been given before the DRP, so the natural justice objection failed, and past treatment in earlier years did not bind the Revenue because there is no res judicata in income-tax proceedings. On the substantive tax issue, receipts from software-linked maintenance support, education and training services were held not taxable as fees for technical services because they were intrinsically connected with the software licences and the Revenue failed to establish the treaty's make available condition. The related service receipts were therefore deleted, and the software licence receipts were not sustained as royalty on the same linked-transaction reasoning. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784485