Software Payments Not Royalty Under Income Tax Law: Karnataka HC

PCIT Vs Blue Yonder Inc (Karnataka High Court) No royalty on software use-Software payments to Blue Yonder not ‘royalty’ – Karnataka HC rejects Revenue’s attempt to reopen settled matter Karnataka High Court dismissed the Revenue’s appeal challenging ITAT Bengaluru’s order dated 03.01.2024 for AY 2019-20 which had held that payments for software usage made to the non-resident assessee were not taxable as “royalty”. The Bench observed that the issue was already concluded in the Assessee’s own cases for earlier years—AYs 2008-09, 2010-11 & 2014-15—where both the Tri...