https://www.taxtmi.com/caselaws?id=469493 Software resale under a non-exclusive, non-transferable licence without transfer of copyright was not royalty, so the distribution receipts were taxable as business income rather than royalty. Management and support services that did not make available technical knowledge, skill, know-how or processes also did not qualify as fees for technical services under the India-Singapore tax treaty, and the more beneficial treaty treatment prevailed. Interest under section 234B was held consequential and leviable, while the challenge to initiation of penalty proceedings under section 270A was premature. The assessee therefore obtained relief on the royalty and management fee issues, but failed on interest and penalty initiation. en-us Tue, 23 Apr 2024 00:00:00 +0530 Fri, 19 Jun 2026 13:11:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469493 Software resale under a non-exclusive, non-transferable licence without transfer of copyright was not royalty, so the distribution receipts were taxable as business income rather than royalty. Management and support services that did not make available technical knowledge, skill, know-how or processes also did not qualify as fees for technical services under the India-Singapore tax treaty, and the more beneficial treaty treatment prevailed. Interest under section 234B was held consequential and leviable, while the challenge to initiation of penalty proceedings under section 270A was premature. The assessee therefore obtained relief on the royalty and management fee issues, but failed on interest and penalty initiation. Case-Laws Income Tax Tue, 23 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469493