Receipts on sale of software not taxable as royalty

IBM Singapore Pte Ltd. Vs DCIT (ITAT Banglore) As per the decision rendered by Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt. Ltd., sale proceeds received by the assessee on sale of software licenses cannot be categorized as “Royalty” within the meaning of provisions of DTAA. FULL TEXT OF THE ORDER OF ITAT BANGALORE These cross appeals are directed against the order dated 28.9.2018 passed by Ld. CIT(A)-12, Bangalore and they relate to the assessment year 2014-15. 2. At the time of hearing, the Ld A.R did not press grounds 2.1 to 2.10 relating to asses...