https://www.taxtmi.com/caselaws?id=793292 Receipts from software product sales and ancillary support services were analysed against the Supreme Court's ruling in Engineering Analysis Centre for Excellence Pvt. Ltd., which held that such software receipts are not taxable as royalty and displaced the earlier jurisdictional High Court view. The note also records that the assessee's earlier years had been decided on the same basis and that the Revenue's review petition had been dismissed, confirming the finality of that legal position. On that footing, the software sales could not be taxed as royalty and the support services could not be treated as fees for technical services; the addition was stated to be unsustainable and the Revenue's appeal to have failed. 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 Receipts from software product sales and ancillary support services were analysed against the Supreme Court's ruling in Engineering Analysis Centre for Excellence Pvt. Ltd., which held that such software receipts are not taxable as royalty and displaced the earlier jurisdictional High Court view. The note also records that the assessee's earlier years had been decided on the same basis and that the Revenue's review petition had been dismissed, confirming the finality of that legal position. On that footing, the software sales could not be taxed as royalty and the support services could not be treated as fees for technical services; the addition was stated to be unsustainable and the Revenue's appeal to have failed. Case-Laws Income Tax Wed, 10 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793292