Income accrued in India - royalty receipts - what is sold is the ...

Income Tax

September 27, 2023

Income accrued in India - royalty receipts - what is sold is the copyrighted software which is shrink-wrapped - the consideration received on the sale of off-the-shelf, shrink-wrapped software to Indian distributors and resellers would not constitute royalty in terms of the India-UK Double Taxation Avoidance Agreement. - no substantial question of law arises - HC

View Source

← Previous Next →

Income accrued in India - royalty receipts - what is sold is the ...

Income Tax

September 27, 2023

You may also like:

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...

Income deemed to accrue or arise in India - Royalty receipt - The assessee is merely a trader of software, hence, has no domain or ownership over the software. Thus,...

Income accrued in India - royalty receipts - transfer of copyright in the software - India-UK DTAA - The Impugned Rulings passed by the learned AAR are set aside and it...

Income from sale of shrink wrap software - consideration received by the Assessee for software was not royalty. The receipts would constitute business receipts in the...

Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of...

Receipt on account of sale of Shrink-wrap software is not in the nature of royalty hence is not liable in India in view of the provision of section 9(1)(iv) of the Act...

IT Computer software after being put on to a media and then sold, becomes goods like any other Audio Cassette or painting, payment cannot be termed as Royalty

Income deemed to accrue or arise in India - Royalty receipt - there was no transfer of copyright in the ‘off the shelf’ sale software; the consideration received thereby...

Income accrued in India - receipts of the assessee from sale of software - In view of Section 90(2) of the Income Tax Act, the assessee opts for Double Taxation...

Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...

Quick Updates: