Income deemed to accrue or arise in India - licensing of ...

Supreme Court: Microsoft's software licenses in India not taxable as royalty u/s 9(1)(vi) and DTAA Article 12.

May 12, 2023

Case Laws Income Tax SC

Income deemed to accrue or arise in India - licensing of software products of Microsoft in the Territory of India by the Respondent was not taxable in India as Royalty under Section 9(1)(vi) read with Article 12 of the Indo US DTAA - this is not Royalty liable to be taxed in India - Revenue appeal dismissed - SC

View Source

← Previous Next →

Income deemed to accrue or arise in India - licensing of ...

Supreme Court: Microsoft's software licenses in India not taxable as royalty u/s 9(1)(vi) and DTAA Article 12.

May 12, 2023

Case Laws Income Tax SC

You may also like:

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....

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...

The case revolves around the taxation of income earned by the assessee from licensing software to Indian customers under the India-USA Double Taxation Avoidance...

Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty...

Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as...

The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts...

Receipts from Indian customers for services provided outside India are not taxable u/s 9(1)(vi) of the Income Tax Act, 1961 read with Article 12 of the India-Singapore...

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...

Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment...

The High Court examined reassessment proceedings involving income from aircraft leasing treated as royalty under the Income Tax Act and India-Ireland Double Taxation...

Income taxable in India - Royalty u/s. 9 and/or under Article- 12 of India - payments made in terms of Sponsorship Agreement - Singapore, DTAA - sponsorship of the ICC...

Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of...

Quick Updates: