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,

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