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2024 (2) TMI 228 - SC ORDERAccrual of income in India - sale of software product - royalty receipts - India USA DTAA - HELD THAT:- Having regard to Order [2024 (2) TMI 137 - SC ORDER] this special leave petition is also dismissed wherein held as Having regard to the judgment of this Court in the case of Engineering Analysis Centre of Excellence Private Limited [2021 (3) TMI 138 - SUPREME COURT] held that amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/suppliers, as consideration for the resale/use of the computer software through EULAs/distribution agreements, is not the payment of royalty for the use of copyright in the computer software, and that the same does not give rise to any income taxable in India.
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