Income from Sale of Software is Business Income & not the Royalty income

Nortonlifelock Inc. Vs ACIT (ITAT Pune) ITAT held that income earned by the assessee from sale of software, either directly to the customers in India or through distributors or resellers constitutes its business income and not the Royalty income and as such business income is not taxable in India as the assessee did not have any Permanent Establishment in India. FULL TEXT OF THE ITAT JUDGEMENT Both the appeals by the assessee filed against the common final assessment order dated 17-06-2020 passed by the Assessing Officer (AO) u/s. 143(3) r.w.s. 147 r.w.s. 144C(1) of the Act for assessment year...