Dismissing the appeal of the revenue the Court held that amount received licence of product which was embedded software is not royalty it is assessable as business income .
CIT ( IT) v. Bently Nevada LLC ( 2020) 114 taxmann.com 101 ( Delhi ) (HC) Editorial: SLP of revenue is dismissed CIT ( IT) v. Bently Nevada LLC ( 2020) 270 Taxman 95 / 114 taxmann.com 102 (SC)
S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Licence embedded software – Not royalty – Assessable as business income [ S.28(i) ]