Income from sale of software not royalty under India-Netherlands income tax treaty: The Mumbai Bench of the Income-tax Appellate Tribunal held that income from the sale of software is not a royalty within the meaning of Article 12(4) of India-Netherlands income tax treaty because the taxpayer did not allow the end-user to use a process under the software. The case is: Baan Global B V. Read a July 2016 report [PDF 280 KB]