https://www.taxtmi.com/caselaws?id=793292 Software product sales and ancillary support service receipts were examined under the Supreme Court's Engineering Analysis ruling, which displaced the earlier High Court view relied upon for taxation. Software sales were not chargeable in India as royalty, and ancillary support services were not taxable as fees for technical services. Consistent treatment in the taxpayer's earlier years and dismissal of the Revenue's review petition reinforced this position. The addition based on characterising these receipts as royalty and fees for technical services was therefore unsustainable, resulting in failure of the Revenue's appeal. en-us Wed, 10 Jun 2026 00:00:00 +0530 Fri, 12 Jun 2026 08:45:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793292 Software product sales and ancillary support service receipts were examined under the Supreme Court's Engineering Analysis ruling, which displaced the earlier High Court view relied upon for taxation. Software sales were not chargeable in India as royalty, and ancillary support services were not taxable as fees for technical services. Consistent treatment in the taxpayer's earlier years and dismissal of the Revenue's review petition reinforced this position. The addition based on characterising these receipts as royalty and fees for technical services was therefore unsustainable, resulting in failure of the Revenue's appeal. Case-Laws Income Tax Wed, 10 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793292