Reselling of Hardware and Software Not ‘Royalty’ under India-Singapore DTAA

Avnet Asia Pte Ltd Vs ACIT (ITAT Delhi) Introduction: The Income Tax Appellate Tribunal (ITAT) in Delhi has delivered a significant verdict in the case of Avnet Asia Pte Ltd Vs ACIT. The central theme revolves around the nature of receipts generated from the reselling of hardware and software packages. Analysis: The Revenue appealed against four separate orders concerning Avnet Asia for the assessment years 2013-14 to 2017-18. The crux of the contention was whether the amounts received from the sale of software and hardware should be categorized as ‘Royalty’ under the India-Singapo...