Software Sale Payment Not Royalty under Indo-Singapore DTAA: Delhi HC

CIT – International Taxation Vs DXC Technology Services Singapore Pte. Ltd. (Delhi High Court) Introduction: The Delhi High Court recently ruled on an appeal filed by CIT – International Taxation-1 against DXC Technology Services Singapore Pte. Ltd. The appeal concerned the Assessment Year 2009-10 and focused on whether payments received for the sale/supply of software could be considered royalty under Article 12(3) of the India-Singapore Double Taxation Avoidance Agreement (DTAA). Detailed Analysis: The dispute originated from the scrutiny-assessment of the respondent/assessee, le...