https://www.taxtmi.com/caselaws?id=469270 For cross-border software and related payments, the treaty definition prevails where more beneficial, and royalty arises only if copyright rights under section 14 of the Copyright Act, 1957 are transferred. Payments for software licences, database access, cloud computing, web hosting and data connectivity were therefore not sustained as royalty on the existing record and were remitted for fresh consideration under Engineering Analysis and the relevant agreements. Consulting, legal, professional, training, certification and sub-contracting charges also required independent examination under the applicable DTAAs to determine whether they were fees for technical services or otherwise not taxable in India. en-us Wed, 25 Aug 2021 00:00:00 +0530 Fri, 12 Jun 2026 17:35:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469270 For cross-border software and related payments, the treaty definition prevails where more beneficial, and royalty arises only if copyright rights under section 14 of the Copyright Act, 1957 are transferred. Payments for software licences, database access, cloud computing, web hosting and data connectivity were therefore not sustained as royalty on the existing record and were remitted for fresh consideration under Engineering Analysis and the relevant agreements. Consulting, legal, professional, training, certification and sub-contracting charges also required independent examination under the applicable DTAAs to determine whether they were fees for technical services or otherwise not taxable in India. Case-Laws Income Tax Wed, 25 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469270