Sale of Software License Not Royalty under India-Singapore DTAA: ITAT Delhi

ACIT Vs Newspage Pvt. Ltd. (ITAT Delhi)

In a significant ruling dated December 8, 2023, the Income Tax Appellate Tribunal (ITAT) Delhi bench clarified the taxability of receipts from the sale of software licenses in the case of ACIT Vs Newspage Pvt. Ltd. This case revolved around whether the income received by Newspage Pvt. Ltd. from Pepsico India Holdings Ltd. and ITC Limited for the sale of software licenses and associated services constituted royalty under Article 12(3) of the India-Singapore Double Taxation Avoidance Agreement (DTAA).

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