https://www.taxtmi.com/caselaws?id=468210 Payments by Indian end-users or distributors to non-resident software suppliers for purchase or licence of software are treated as not constituting royalty under section 9(1)(vi), so no tax deduction issue arises under section 195 and disallowance under section 40(a)(ia) is not sustainable. Employees' contribution to provident fund paid on or before the due date for filing the return remains allowable and is not disallowable. Overdue receivables from associated enterprises beyond the credit period may constitute an international transaction under section 92B, and benchmarking of notional interest is to be made on LIBOR plus an appropriate spread, with LIBOR plus 200 basis points applied here. en-us Fri, 27 May 2022 00:00:00 +0530 Wed, 22 Apr 2026 17:32:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468210 Payments by Indian end-users or distributors to non-resident software suppliers for purchase or licence of software are treated as not constituting royalty under section 9(1)(vi), so no tax deduction issue arises under section 195 and disallowance under section 40(a)(ia) is not sustainable. Employees' contribution to provident fund paid on or before the due date for filing the return remains allowable and is not disallowable. Overdue receivables from associated enterprises beyond the credit period may constitute an international transaction under section 92B, and benchmarking of notional interest is to be made on LIBOR plus an appropriate spread, with LIBOR plus 200 basis points applied here. Case-Laws Income Tax Fri, 27 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468210