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India Supreme Court in Landmark Ruling: Software Payments are Not Royalties

|Approved Changes|India
India

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 Indian companies act as distributors or resellers by purchasing computer software from non-resident sup…

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