https://www.taxtmi.com/caselaws?id=785242 Consideration received for licensing Customer Relationship Management software was treated by the Delhi High Court as not constituting royalty income under Article 12(3) of the India-Singapore DTAA, so the tax issue was decided in favour of the assessee. The Supreme Court declined to interfere under Article 136 and dismissed the special leave petitions, leaving the High Court's view undisturbed. en-us Fri, 16 Jan 2026 00:00:00 +0530 Tue, 20 Jan 2026 06:31:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785242 Consideration received for licensing Customer Relationship Management software was treated by the Delhi High Court as not constituting royalty income under Article 12(3) of the India-Singapore DTAA, so the tax issue was decided in favour of the assessee. The Supreme Court declined to interfere under Article 136 and dismissed the special leave petitions, leaving the High Court's view undisturbed. Case-Laws Income Tax Fri, 16 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785242