2024 (2) TMI 137

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..... s 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, as a result of which the persons referred .....

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..... owing. Delay in filing the special leave petition is condoned. Having regard to the judgment of this Court in the case of Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income Tax and Anr. reported in (2022) 3 SCC 321 and having regard to the order of this Court dated 03.07.2023 passed in SLP (C) Dy. No.16749/2023, the present special leave petition stands, acc .....

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