Reviewed case brief

Engineering Analysis Centre of Excellence v CIT

[VERIFY]

[VERIFY] · Supreme Court of India

taxation-lawroyaltysoftwaresection-9dtaa
Court
Supreme Court of India
Year
2021
Subjects
Law of Taxation
Reviewed
2026-08-02

Rule established

Payment for use of computer software (not source code) is not 'royalty' under S.9(1)(vi); it is business income not taxable in India without PE.

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        [VERIFY]

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