https://www.taxtmi.com/caselaws?id=801715 Consideration from Indian customers for standard software is characterised as business income rather than royalty. Under Article 7 of the India-US tax treaty, that income is not taxable in India where no permanent establishment exists. In the absence of material changes in facts, agreements, or applicable law from the preceding assessment year, the principle of consistency supports continuing the earlier characterisation and non-taxability. en-us Tue, 08 Sep 2026 00:00:00 +0530 Mon, 26 Oct 2026 08:05:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801715 Consideration from Indian customers for standard software is characterised as business income rather than royalty. Under Article 7 of the India-US tax treaty, that income is not taxable in India where no permanent establishment exists. In the absence of material changes in facts, agreements, or applicable law from the preceding assessment year, the principle of consistency supports continuing the earlier characterisation and non-taxability. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801715