Consideration for mere resale/use of computer software through EULAs/distribution agreements is not Royalty

GE Intelligent Platforms Asia Pacific Pte Ltd Vs A.C.I.T (ITAT Delhi) ITAT held that amounts 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 to in section 195 of the Income Tax Act were not liable to deduct any TDS under section 195 of the Income T...