https://www.taxtmi.com/caselaws?id=468504 Royalty and fees for technical services were analysed under the treaty framework as taxable on receipt basis, and the assessment on accrual basis was rejected in line with earlier decisions in the assessee's own case. Consideration for supply of software was held not to constitute royalty where the arrangement involved only a restricted, non-exclusive licence without transfer of copyright, so the receipts were not taxable as royalty under either the Act or the treaty. The transfer pricing adjustment on technical service transactions was also deleted because the arm's length price had been fixed by an ad hoc uplift without a proper method-based analysis, and the record disclosed no defect in the assessee's study. en-us Mon, 16 Jun 2025 00:00:00 +0530 Sat, 09 May 2026 10:32:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468504 Royalty and fees for technical services were analysed under the treaty framework as taxable on receipt basis, and the assessment on accrual basis was rejected in line with earlier decisions in the assessee's own case. Consideration for supply of software was held not to constitute royalty where the arrangement involved only a restricted, non-exclusive licence without transfer of copyright, so the receipts were not taxable as royalty under either the Act or the treaty. The transfer pricing adjustment on technical service transactions was also deleted because the arm's length price had been fixed by an ad hoc uplift without a proper method-based analysis, and the record disclosed no defect in the assessee's study. Case-Laws Income Tax Mon, 16 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468504