https://www.taxtmi.com/caselaws?id=791347 Royalty and fee for technical services were treated as taxable on receipt basis under the applicable treaty, following the assessee's earlier years where identical facts were found. Consideration for supply of software was held not to constitute royalty because the software was supplied under limited licence terms without transfer of copyright rights. The consortium arrangement did not amount to an association of persons, as the parties had separate scopes of work, separate invoicing, no profit-sharing or common management, and only contractual joint liability. Offshore supply receipts were held not taxable in India, transfer pricing adjustments based on an ad hoc markup were deleted, and interest from NTPC was treated as not taxable in the relevant year. en-us Wed, 29 Apr 2026 00:00:00 +0530 Sat, 09 May 2026 07:13:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791347 Royalty and fee for technical services were treated as taxable on receipt basis under the applicable treaty, following the assessee's earlier years where identical facts were found. Consideration for supply of software was held not to constitute royalty because the software was supplied under limited licence terms without transfer of copyright rights. The consortium arrangement did not amount to an association of persons, as the parties had separate scopes of work, separate invoicing, no profit-sharing or common management, and only contractual joint liability. Offshore supply receipts were held not taxable in India, transfer pricing adjustments based on an ad hoc markup were deleted, and interest from NTPC was treated as not taxable in the relevant year. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791347