https://www.taxtmi.com/caselaws?id=794405 A non-transferable software subscription conferring only limited access for a customer's own business use, without transfer of copyright, technology, or technical know-how, is not taxable as royalty or fee for technical services under the Act or the India-USA DTAA. Separately charged professional services that were customer-specific and involved specialised technical and professional inputs were held taxable as fee for technical services. As only the professional-services receipts were sustained, proportionate relief was allowed for equalisation levy on receipts not brought to tax, with surcharge and interest treated as consequential. en-us Mon, 29 Jun 2026 00:00:00 +0530 Sat, 04 Jul 2026 10:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794405 A non-transferable software subscription conferring only limited access for a customer's own business use, without transfer of copyright, technology, or technical know-how, is not taxable as royalty or fee for technical services under the Act or the India-USA DTAA. Separately charged professional services that were customer-specific and involved specialised technical and professional inputs were held taxable as fee for technical services. As only the professional-services receipts were sustained, proportionate relief was allowed for equalisation levy on receipts not brought to tax, with surcharge and interest treated as consequential. Case-Laws Income Tax Mon, 29 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794405