https://www.taxtmi.com/highlights?id=101386 ITAT held that software subscription receipts were consideration for access to a copyrighted article, not royalty or fees for technical/included services, because customers received only a non-transferable right to use the software and no technology was transferred or made available. That treatment applied to AYs 2020-21 to 2022-23. By contrast, separate professional services receipts in AY 2022-23 were found to be specialised, customer-specific technical and professional consultations, so they were taxable as FTS/FIS under the Act and the DTAA. Proportionate equalization levy paid on those taxable services was directed to be refunded. en-us Sat, 04 Jul 2026 08:15:43 +0530 Sat, 04 Jul 2026 08:15:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101386 ITAT held that software subscription receipts were consideration for access to a copyrighted article, not royalty or fees for technical/included services, because customers received only a non-transferable right to use the software and no technology was transferred or made available. That treatment applied to AYs 2020-21 to 2022-23. By contrast, separate professional services receipts in AY 2022-23 were found to be specialised, customer-specific technical and professional consultations, so they were taxable as FTS/FIS under the Act and the DTAA. Proportionate equalization levy paid on those taxable services was directed to be refunded. Highlights Income Tax Sat, 04 Jul 2026 08:15:43 +0530 https://www.taxtmi.com/highlights?id=101386