https://www.taxtmi.com/caselaws?id=466673 Royalty and fees for technical services were held taxable only on receipt where the applicable treaty provision required actual receipt, so accrual-based taxation was rejected. The value of software supplied as an inseparable part of equipment was not treated as royalty, because the software was not separately sold and the embedded-use principle applied. Interest under section 234B was held not leviable where the income was wholly subject to tax deduction at source, since no advance tax liability arose. The disputed additions and interest adjustment were therefore decided in favour of the assessee. en-us Fri, 30 May 2014 00:00:00 +0530 Mon, 16 Feb 2026 20:10:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466673 Royalty and fees for technical services were held taxable only on receipt where the applicable treaty provision required actual receipt, so accrual-based taxation was rejected. The value of software supplied as an inseparable part of equipment was not treated as royalty, because the software was not separately sold and the embedded-use principle applied. Interest under section 234B was held not leviable where the income was wholly subject to tax deduction at source, since no advance tax liability arose. The disputed additions and interest adjustment were therefore decided in favour of the assessee. Case-Laws Income Tax Fri, 30 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466673