Supreme Court of India

Engineering Analysis Centre of Excellence Private Limited v. The Commissioner of Income Tax & Anr.

Neutral citation
Reported as [2021] 2 S.C.R. 321
Bench R. F. Nariman, Hemant Gupta and B. R. Ga V Ai JJ.
Decided 2 March 2021

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

From the headnote

Income Tax Act, 1961: s.195 – Amount paid by reside nt in India to non-resident foreign software suppliers – Liabil ity to deduct tax at source – Held: In view of the definition of roy alties contained in Article 12 of the DTAAs, there is no obligation on the persons mentioned in s. 195 of the Income Tax Act to deduct tax at source, as the distribution agreements/EULAs in the facts of these c ases do not create any interest or right in such distributors/end-u sers, which would amount to the use of or right to use any copy right – The amounts paid by resident Indian end-users/distribut ors to

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