https://www.taxtmi.com/caselaws?id=466656 The High Court confined the appeal to the single legal issue whether payments for licensing software constitute royalty, admitting that question for substantive hearing; it recorded that related issues on taxability on receipt versus accrual and deletion of interest charges are foreclosed by existing precedent and therefore not entertained in this appeal. Operative effect: the appeal proceeds only on the characterisation question of software-license receipts as royalty, and no final determination on that question is recorded in the order. en-us Mon, 22 Oct 2012 00:00:00 +0530 Mon, 16 Feb 2026 14:19:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466656 The High Court confined the appeal to the single legal issue whether payments for licensing software constitute royalty, admitting that question for substantive hearing; it recorded that related issues on taxability on receipt versus accrual and deletion of interest charges are foreclosed by existing precedent and therefore not entertained in this appeal. Operative effect: the appeal proceeds only on the characterisation question of software-license receipts as royalty, and no final determination on that question is recorded in the order. Case-Laws Income Tax Mon, 22 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466656