Reviewed case brief
Engineering Analysis Centre of Excellence v CIT
[VERIFY]
[VERIFY] · Supreme Court of India
- 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]
Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.