Amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/suppliers, as consideration for the resale/use of the computer software, not royalty, hence, not taxable in India. The end user does not get any of the rights that the owner continues to retain under Section 14(b) of the Copyrights Act read with sub sections (a)(i)-(vii) therof.

[Engineering Analysis Centre of Excellence (P) Ltd. v. CIT, (2022) 3 SCC 321]

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