Do software payments amount to royalties? Tracing the answer in the context of the engineering analysis case and proposing an alternative model

After almost two decades of litigation characterizing software payments for income taxation, the Hon’ble Supreme Court India delivered a judgment on batch over hundred appeals before it. The respited taxpayers. present article analyzes various arguments presented by taxpayers and Revenue Department tests their applicability touchstone International Indian legal provisions established understanding copyright law. concludes that impact law taxation cannot be avoided any exploitation leading to income-generation is subject tax. However, instead bypassing laws, correct interpretation nuances laws would lead more effective less debilitating results.