https://www.taxtmi.com/caselaws?id=796187 Software purchase payments to non-residents were described as not constituting royalty and therefore not requiring withholding under section 195, consistent with the Karnataka High Court decision referred to in the text. The Supreme Court did not examine that substantive characterisation: it found the reasons for a 307-day delay in filing the Special Leave Petition unsatisfactory and legally insufficient, dismissed the condonation application, and consequently dismissed the Special Leave Petition solely on delay. en-us Wed, 29 Jul 2026 00:00:00 +0530 Sat, 01 Aug 2026 08:34:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796187 Software purchase payments to non-residents were described as not constituting royalty and therefore not requiring withholding under section 195, consistent with the Karnataka High Court decision referred to in the text. The Supreme Court did not examine that substantive characterisation: it found the reasons for a 307-day delay in filing the Special Leave Petition unsatisfactory and legally insufficient, dismissed the condonation application, and consequently dismissed the Special Leave Petition solely on delay. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796187