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7.10 "The software as it is seen in the present context can be classified as a process and therefore applicability of the judgement is not direct is this case. A clam of softwares are basically classifiable as a "process" or plan and the consideration of the same is certainly consideration for a process as included in the definition of Royalty in the DTAA. The term process used here is not in the context of the manner of writing a computer program. The Delhi Tribunal had discussed the classification of process related to software royalty by stating the source code was not transferred therefore there is no royalty as the process was not shared. The journals under consideration do share an information concerning industrial, 37 | P a g e commercial or scientific experience and therefore, the consideration thereof is taxable as "Royalty".