Software licensing ancillary services and deemed Indian accrual are assessed under principles governing technical-service income.

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....Receipts from ancillary services connected with software licensing are considered in relation to their characterisation as fees for technical services and deemed accrual of income in India under section 9(1)(vi). The note records that the Tribunal's approach for a later assessment year relied on the Supreme Court's Engineering Analysis decision, whose review was subsequently dismissed. It further notes that no substantial question of law arose from the challenged order.....