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    Upholding Precedent: Supreme Court's Stance on Taxation of Cross-Border Software Payments (Royalty)
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    Case LawsIncome Tax
    Upholding Precedent: Supreme Court's Stance on Taxation of Cross-Border Software Payments (Royalty)
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    Taxation of cross border software payments as royalty reinforced; precedent remains binding despite pending review, so withholding obligations persist.
    Supreme Court reaffirmed that payments to non residents for software are to be treated as royalty for withholding tax purposes, holding that a pending review against an earlier precedent does not suspend that precedent's application; procedural limits on review under the Code of Civil Procedure prevent indefinite postponement of settled law, requiring taxpayers and payors in cross border software transactions to comply with prevailing withholding obligations.

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