https://www.taxtmi.com/caselaws?id=791876 Royalty-related TDS under section 195 was considered in the context of income deemed to accrue in India under section 9(1)(vi), DTAA interpretation, end-user licence and distribution agreements, and the distinction between copyright and a copyrighted article, including the doctrine of first sale or exhaustion, the retrospective impact of Explanation 4 to section 9(1)(vi), and proportionality under section 195(2). The matter was treated as covered by the Supreme Court's ruling in Engineering Analysis Centre of Excellence Private Limited, and no further issue survived; the special leave petition was dismissed. en-us Fri, 15 May 2026 00:00:00 +0530 Tue, 19 May 2026 08:18:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791876 Royalty-related TDS under section 195 was considered in the context of income deemed to accrue in India under section 9(1)(vi), DTAA interpretation, end-user licence and distribution agreements, and the distinction between copyright and a copyrighted article, including the doctrine of first sale or exhaustion, the retrospective impact of Explanation 4 to section 9(1)(vi), and proportionality under section 195(2). The matter was treated as covered by the Supreme Court's ruling in Engineering Analysis Centre of Excellence Private Limited, and no further issue survived; the special leave petition was dismissed. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791876