Payments for resale or use of software under EULAs not taxable as royalty under Income Tax Act Section 195

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....The HC held that consideration received for resale or use of computer software under EULAs or distribution agreements does not constitute royalty income arising in India. Consequently, such receipts are not taxable as royalty under the Income Tax Act. The court relied on precedent to determine that no income accrues or arises in India from these transactions. Therefore, persons liable under section 195 of the Act were not required to deduct tax at source on such payments. The assessee's appeal was allowed, relieving them from the obligation to withhold tax on these payments.....