Income from sale of software constitutes business income instead of royalty in absence of PE

Norton Lifelock Inc. Vs DCIT (IT) (ITAT Pune)

Conclusion: Income earned by assessee from sale of software, either directly to the customers in India or through Distributors or Resellers constituted its business income and not the Royalty income. As admittedly assessee did not have any Permanent Establishment in India, such income will not magnetize Indian taxation.

Held:  Assessee earned revenue from sale of software licenses in India including certificat

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