https://www.taxtmi.com/caselaws?id=469495 Receipts from distribution of off-the-shelf software required fresh adjudication on their correct tax character under the governing treaty and Supreme Court guidance, because the arrangement was non-exclusive and non-transferable and the earlier return position did not control the legal classification; the software issue was remanded to the Assessing Officer. Management fee for managerial, operational, support and advisory services was not taxable as fee for technical services under the India-Singapore DTAA, because the services did not make available technical knowledge, skill, know-how or processes, and the more beneficial treaty provisions prevailed over the broader domestic definition. en-us Mon, 21 Aug 2023 00:00:00 +0530 Fri, 19 Jun 2026 13:27:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469495 Receipts from distribution of off-the-shelf software required fresh adjudication on their correct tax character under the governing treaty and Supreme Court guidance, because the arrangement was non-exclusive and non-transferable and the earlier return position did not control the legal classification; the software issue was remanded to the Assessing Officer. Management fee for managerial, operational, support and advisory services was not taxable as fee for technical services under the India-Singapore DTAA, because the services did not make available technical knowledge, skill, know-how or processes, and the more beneficial treaty provisions prevailed over the broader domestic definition. Case-Laws Income Tax Mon, 21 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469495