Software License Fees Paid to UK Company Not Taxable as Royalty: Karnataka HC

PCIT Vs Syna Media Limited (Karnataka High Court) The Karnataka High Court, in the case of PCIT vs. Syna Media Limited, dismissed an appeal by the Income Tax Department, affirming that payments received by Syna Media Limited for software licenses and hardware were not taxable as royalty. This decision, concerning the assessment year 2021-22, was based on the premise that the agreements granted customers a non-exclusive and non-transferable license to use the software, but did not involve the transfer of any intellectual property rights (IPR). The court’s judgment aligned with the established...