India Supreme Court in Landmark Ruling: Software Payments are Not Royalties
The Supreme Court of India on 1 March 2021 issued a landmark decision in the Software case, which bundles several challenges to the taxability of software payments to non-residents. The Supreme Court bundled the challenges in 4 categories as follows:
- Cases where computer software is purchased directly by a resident end-user from a non-resident supplier or manufacturer;
- Cases where resident Ind…