Case of CIT International Taxation vs Xiacom (NZ) Ltd, HC Delhi Judgement Dated 12th August 2025. HC held that consideration for the resale/use of computer software through EULAs (End User Licence Agreement) /distribution agreement is not Royalty for the use of copyright of the computer software and hence doesn’t give rise to any taxable income in India. Hence, TDS under section 195 not deductible.