Cross-border payment for software not royalty, SC ends two-decade old tax dispute SC says there is no obligation on a person to deduct tax at source, as the end-user licence agreements in these cases do not create any interest or right in such end-users, which would amount to the use of or right to use any copyright Dipak Mondal | March 3, 2021 | Updated 13:35 IST Tax experts hailed the SC order, saying the judgment would have a far-reaching impact The Supreme Court has put an end to an over two-decade-old software royalty tax dispute after it ruled that cross-border payments made for the sale of software to a non-resident are not to be taxed as "royalty".