Amounts paid to foreign suppliers for use of computer software through distribution agreement is not Royalty

DCIT Vs Adobe Systems Software Ireland Ltd. (ITAT Delhi)

Conclusion: In present facts of the case, the Hon’ble ITAT by relying upon the Judgment of Hon’ble Supreme Court on the issue of Royalty observed that the 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 are not the payment of Royalty for the purpose of copyright in the computer software, and the same do not

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