Tribunal held that on a reading of the terms of the agreement, it was clear that there was no right to use the computer software. The receipts from sale of computer software to Indian distributors and end users with ancillary services could not be brought to tax in India. (AY. 2014-15)
Autodesk Asia Pte Ltd. v. Dy.CIT(IT) (2021) 91 ITR 1 (SN) (Bang.) (Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Non-Resident-Receipts from sale of computer software to Indian distributors and end users with ancillary services not taxable in India.