TDS not deductible on payment for making use of shrink wrap computer software

S&P Capital IQ (India) Private Limited Vs DCIT (ITAT Hyderabad) ITAT Hyderabad held that payments made for making use of shrink wrap computer software wherein there is no transfer of any copyright nor grant of any commercial right to exploit it doesn’t fall within the definition of royalty and hence TDS not deductible. Facts- The assessee Company is engaged in the business of providing Information Technology Enabled Services (ITES) to its parent company S&P Global Market Intelligence LLC, USA (earlier known as Capital IQ Inc., USA). During the year under consideration, the assessee h...