https://www.taxtmi.com/caselaws?id=798122 Royalty treatment under a DTAA was raised in relation to payments for computer software supplied under a non-exclusive, non-transferable licence. The issue concerned whether such arrangements confer copyright rights, particularly a right to reproduce the software, or merely permit use of off-the-shelf or shrink-wrapped software. The Special Leave Petition was dismissed because similar Special Leave Petitions had been dismissed. en-us Mon, 24 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798122 Royalty treatment under a DTAA was raised in relation to payments for computer software supplied under a non-exclusive, non-transferable licence. The issue concerned whether such arrangements confer copyright rights, particularly a right to reproduce the software, or merely permit use of off-the-shelf or shrink-wrapped software. The Special Leave Petition was dismissed because similar Special Leave Petitions had been dismissed. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798122