Income received from sale of software licenses - Royalty - the ...

Income Tax

September 2, 2020

Income received from sale of software licenses - Royalty - the amended definition of Royalty under the domestic law even if amended with retrospective effect cannot be extended to the definition of “Royalty” under the DTAA since the term “Royalty” under the DTAA has not been amended. As the provision of DTAA over-ride the provision of Income Tax Act, 1961 and being more beneficial shall apply - AT

View Source

← Previous Next →

Income received from sale of software licenses - Royalty - the ...

Income Tax

September 2, 2020

You may also like:

Consideration received by the assessee on sale of software is not chargeable to tax as royalty such as equipment royalty, process royalty etc - AT

Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT...

Transactions under a software license agreement - The license charges earned by assessee was not liable to be treated as royalty.

Classification of services - Information Technology software services or not - sale of canned software with license and condition to upgrade the said software - The...

Supply of software on licence - Taxability in India - If the receipts cannot be taxed under the treaty as royalty, then it cannot be taxed under the domestic law under...

The license granted by Oracle Data Base for use of its software by the assessee company constitutes royalty - TDS required to be deducted .... - AT

Accrual of income in India - Royalty / FTS - the software maintenance fees, consulting charges and training fees which are incidental to software license fee, assumes...

Taxation of software reimbursements as Royalty - assessee strongly contends that reimbursements sought by the assessee represent recovery of expenses incurred by it, on...

Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

TDS - In the present case, income towards sale of software to the Indian “AE” cannot be treated as “Royalty”. - AT

Quick Updates: