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<h1>Bombay High Court: Software payments to foreign companies not taxable as 'royalty' u/s 9(1)(vi) of Income Tax Act.</h1> The Bombay High Court ruled that remittances made by an Indian company to foreign entities for purchasing computer software are not taxable as 'royalty' under Section 9(1)(vi) of the Income Tax Act, 1961. This decision aligns with the Supreme Court's ruling in Engineering Analysis Centre of Excellence (P.) Ltd., which determined that such transactions do not create any rights to use copyrights, thereby exempting them from royalty taxation. The Court dismissed the Revenue's appeals, confirming that the remittances fall under the purview of Double Taxation Avoidance Agreements and are not subject to tax as royalties.
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