Dismissing the appeal of the revenue the court held that consideration received by assessee, a UK based company from various entities on account of sale of software product was not royalty within meaning of Article 13 of India UK DTAA. (AY. 2010-11, 2013-14)
CIT(IT) v. Micro Focus Ltd. (2021) 279 Taxman 242 (Delhi)(HC)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Sale of software-Not royalty-DTAA-India-UK. [Art. 13]