Income from Software Sublicensing to Indian Affiliates Ruled as Business Income, Not Taxable Without Permanent Establishment.

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....Accrual of income in India - taxability of the “software” supplied to Indian affiliates - The Tribunal's decision effectively overturns the AO's and DRP's stance, particularly concerning the taxability of income from the sublicensing of software. By classifying this income as business income and acknowledging the lack of a PE in India, the Tribunal aligns its decision with the Supreme Court's interpretation, thereby granting relief to the assessee. This judgment underscores the nuanced understanding required in the taxation of international transactions, especially in the rapidly evolving tech sector.....