Supreme Court reaffirms non-Taxable Nature of Receipts for Computer Software Access to Member Firms

The Supreme Court dismissed a special leave petition filed by the Income Tax Department, affirming that payments received for providing access to computer software by member firms are not taxable as "royalty." The case revolved around the taxability of receipts under Section 195 of the Income Tax Act. The Supreme Court supported the Delhi High Court’s earlier decision, emphasizing that such payments do not qualify as royalty under India's Double Taxation Avoidance Agreements (DTAA). This judgment reiterates the principle that software access fees are non-taxable in specific cross-border contexts.