Amount paid by resident Indian distributors to non-resident computer software manufacturers/suppliers is not payment of royalty

Last updated: 18 June 2021

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The Income Tax Appellate Tribunal has ruled that payments made by resident Indian distributors to non-resident computer software manufacturers are not considered royalty. This decision clarifies that such transactions, even when involving software and hardware, do not fall under the definition of royalty for tax purposes under Indian law and the India-Singapore Double Taxation Avoidance Agreement.

Court :
ITAT Bangalore

Brief :
Present appeal has filed by assessee against order dated 31/11/2020 passed by the ITO (Intl. Taxation), Circle-1, Bangalore for assessment years 2017-18 on following grounds of appeal:-

Citation :
IT(IT)A No.27/Bang/2021

Daily Limit Reached