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High Court of Karnataka Dismisses Revenue's Appeal in TDS Dispute — Payment to Non-Resident for Software Not Royalty. Payment for purchase of shrink-wrapped software from non-resident held not royalty under Section 9(1)(vi) of Income Tax Act, 1961, as no copyright transferred.

The case involves two appeals filed by the Revenue under Section 260-A of the Income Tax Act, 1961, against the common order of the Income Tax Appella...

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High Court of Karnataka Dismisses Revenue's Appeal in TDS Dispute — Payment to Non-Resident for Software Not Royalty Under Section 9(1)(vi) of Income Tax Act, 1961. Payment for shrink-wrapped software held to be for copyright article, not transfer of copyright rights, thus not taxable as royalty.

The case involves two appeals filed by the Revenue (Commissioner of Income Tax and Deputy Commissioner of Income Tax (TDS)) against the common order o...

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Supreme Court Dismisses Assessee's Appeal in Income Tax Case Regarding Exemption Under Section 4(3)(vii) of Income-tax Act, 1922. Receipt Held to be Business Income, Not Exempt as Casual or Non-Recurring Receipt, as it Arose from Services Rendered in the Course of Business.

The assessee firm, Ram Kumar Agarwalla and Brothers, carried on business as share brokers and paper merchants. Together with D, a chartered accountant...