https://www.taxtmi.com/caselaws?id=466187 No permanent establishment or business connection in India was found where the contractual arrangements were concluded outside India, the assessee's role was limited to supply of hardware from Italy, and the Indian subsidiary's onshore activities had already been offered to tax; the Revenue's challenge on taxability in India therefore failed. Consideration for licensing the right to use software was not taxable as royalty because the issue was governed by the Supreme Court ruling in Engineering Analysis Centre of Excellence (P) Ltd., which treats such payments as outside royalty where the user acquires mere software use rights. No separate substantive reasoning was recorded on interest under section 234B. en-us Mon, 27 Jan 2025 00:00:00 +0530 Wed, 28 Jan 2026 13:57:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466187 No permanent establishment or business connection in India was found where the contractual arrangements were concluded outside India, the assessee's role was limited to supply of hardware from Italy, and the Indian subsidiary's onshore activities had already been offered to tax; the Revenue's challenge on taxability in India therefore failed. Consideration for licensing the right to use software was not taxable as royalty because the issue was governed by the Supreme Court ruling in Engineering Analysis Centre of Excellence (P) Ltd., which treats such payments as outside royalty where the user acquires mere software use rights. No separate substantive reasoning was recorded on interest under section 234B. Case-Laws Income Tax Mon, 27 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466187