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Case Lawsuit Title
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Case / Trial ID Number
Jurisdiction Code
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us
in
upc
eu
Category
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Patent
Trademark
Copyright
Design
Filing Date
Decision Verdict Date
Court / Tribunal
Bench / Panel Judges
Petitioner / Claimant (Plaintiff)
Director Of Income Tax
Respondent / Defendant
Infrasoft Ltd.
Dispute Summary
The dispute centered on whether payments received by Infrasoft Ltd. for licensing its civil engineering software constituted royalty income under the India-US Double Taxation Avoidance Agreement (DTAA). The Assessing Officer had taxed these receipts as royalty, leading to an appeal by the Director of Income Tax. The Delhi High Court ultimately ruled in favor of Infrasoft, holding that the payment was merely for a limited right to use the copyrighted material, not the copyright itself, and thus qualified as business income.
Outcome / Ruling
defendant_favorable
Verdict Document PDF URL
Full text judgment
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