Income accrued in India - royalty receipts - transfer of ...

UK Software Payments to India Not Taxable as Royalty, Says High Court; Overturns AAR Ruling Under Income Tax Act.

December 14, 2021

Case Laws Income Tax HC

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 is held that the payment received by EYGSL (UK) for providing access to computer software to its member firms of EY Network located in India, that is, EYGBS (India), does not amount to “royalty” liable to be taxed in India under the provisions of the Income Tax Act, 1961 and the India-UK DTAA. - HC

View Source

← Previous Next →

Income accrued in India - royalty receipts - transfer of ...

UK Software Payments to India Not Taxable as Royalty, Says High Court; Overturns AAR Ruling Under Income Tax Act.

December 14, 2021

Case Laws Income Tax HC

You may also like:

Royalty income payments made by the assessee for obtaining computer software were not liable to be taxed in India as royalty u/s 9(1)(6). The amounts paid by resident...

TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee...

The assessee, a non-resident company incorporated in Singapore without a permanent establishment in India, received income from licensing of software to M/s. L&T Ltd....

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...

TDS u/s 195 - Royalty - the amounts paid by resident Indian endusers/ distributors to non-resident computer software manufacturers/suppliers, as consideration for the...

The assessee company is eligible to claim Foreign Tax Credit (FTC) against its Minimum Alternate Tax (MAT) liability u/s 115JB of the Income Tax Act for taxes paid in...

The ITAT ruled that receipts from Business Support Services (BSS) should be deleted from the assessee's taxable income, following binding precedent established in the...

Income taxable in India - cellular roaming charges - India-UK DTAA under Article 13(3) - Royalty - VIL already possessed the process used for providing roaming services...

The High Court examined whether payments made by an Indian company to its associated entity in the US for supply of computer software constituted "royalty" under the...

The appellant qualified as a non-resident in India during the previous year 2015-16. A non-resident is taxable in India only for income received/deemed to be received or...

Non-resident individual seconded on overseas assignment to UK - Salary received for employment exercised in UK taxable only in UK under Article 15(1) of India-UK DTAA,...

Payments made by the respondent for obtaining computer software were not liable to be taxed in India as royalties u/s 9(1)(vi) of the Income Tax Act, 1961. Following...

TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

The ITAT ruled that the salary received by the assessee for an international assignment to the UK, being a resident of the UK and a non-resident of India, is not taxable...

Quick Updates: