Receipts from sale of software licenses are not royalty income

UT Starcom Inc Vs ACIT (ITAT Delhi)

ITAT Delhi held that the receipts from sale of software licenses are not in the nature of royalty income. Also held that, though, such income may be in the nature of business profit, however, no part of which can be attributed to the PE in India.

Facts- The assessee is a non-resident corporate entity and a tax resident of USA. The assessee is engaged, inter alia, in the business of developing and marketing of telecommunication equipments

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