https://www.taxtmi.com/caselaws?id=785665 The article concerns the taxability of payments for computer software under section 9 of the Income Tax Act, including whether a non-resident had a business connection or permanent establishment in India and whether consideration for software licences constituted royalty. It notes the Delhi High Court view that resident end-users or distributors' payments to non-resident software suppliers for resale or use of software under EULAs and distribution agreements do not amount to royalty for use of copyright and do not create taxable income in India. The Supreme Court declined to interfere with that judgment, and the special leave petitions were dismissed. en-us Tue, 27 Jan 2026 00:00:00 +0530 Thu, 29 Jan 2026 09:51:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785665 The article concerns the taxability of payments for computer software under section 9 of the Income Tax Act, including whether a non-resident had a business connection or permanent establishment in India and whether consideration for software licences constituted royalty. It notes the Delhi High Court view that resident end-users or distributors' payments to non-resident software suppliers for resale or use of software under EULAs and distribution agreements do not amount to royalty for use of copyright and do not create taxable income in India. The Supreme Court declined to interfere with that judgment, and the special leave petitions were dismissed. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785665