OrbitaxTreaty between India and UK – Indian decision on whether payments for software constitutes royalty or business income
|Treaty Development|India-United Kingdom
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 19 December 2008 in the case of Infrasoft Ltd. v. ADIT (International Tax) (ITA No. 847/Del/2008) on whether payments for customized software should be taxed as "royalty" or "business profits".
(a) Facts. The Taxpayer (i.e. Infrasoft Ltd.) was a marketing and development company incorporated …
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