DTAA Overrides Domestic Law – Tribunal Quashes Royalty Addition on ₹151.83 Cr Software Sales

Dassault Systemes SolidWorks Corporation Vs ACIT (ITAT Mumbai) DTAA Overrides Domestic Law – Tribunal Quashes Royalty Addition on ₹151.83 Cr Software Sales; ITAT Mumbai: Sale of Shrink-Wrapped Software Not Taxable as Royalty – Relief to Dassault SolidWorks Background Assessee, a US tax resident, develops & markets 3D mechanical design software. Entered into distribution agreements with Indian resellers who buy software & resell to end-users. For AY 2022-23: Offered ₹29.7 lakh as royalty income (taxed @10% under Act). Offered ₹66.7 lakh as interest on IT refund (taxed @15% ...