Receipts for sale of software licenses & provision of ancillary support services cannot be assessed as royalty income

Informatica Business Solutions Pvt. Ltd. Vs DCIT (ITAT Bangalore) Assessee has sold software products and also received income for providing support services. He submitted that providing ancillary support services is also related to sale of software products only. He submitted that the decision rendered by Hon’ble Karnataka High Court in the case of Samsung Electronics Company Ltd. (supra), which was relied upon by the AO, has since been reversed by Hon’ble Supreme Court in the case of Engineering Analysis Centre for Excellence Pvt. Ltd. (432 ITR 471). The Ld. A.R. further submitted that a...