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Informative

Consideration for Software Resale/Use via EULAs Not Royalty, No TDS Liability u/s 195: Delhi HC...

Update / Judgement Date

20 Aug 2025

Source

Taxscan

Author

Team — WCP Legal Desk

Reading Time

1 min read

Income TaxInternational Taxation

The Delhi High Court has ruled that "consideration for software resale/use via EULAs is not royalty" and there is "no TDS liability under Section 195." The court's decision provides a significant victory for the taxpayer. The ruling clarifies that a payment that is for the use of a software is not a royalty.