On Monday, the Supreme Court of India rejected the income tax department's review petitions challenging its March 2021 ruling that exempted payments made to foreign software companies from being taxed as royalty. The tax department argued that such payments constituted royalty due to the licensing of software copyrights. However, the three-judge bench, consisting of Justices Sanjay Kumar, KV Viswanathan, and K Vinod Chandran, noted that the court had previously dismissed similar petitions in April 2024, emphasizing that it would not be appropriate to reopen the issue. The 2021 ruling clarified that end-user license agreements do not transfer copyright, granting only a non-exclusive license for resale. This decision has significantly lowered software acquisition costs for Indian companies, allowing overseas sellers to reduce prices. Key beneficiaries include firms like IBM India, Samsung Electronics, and Hewlett Packard India. The principles established in the 2021 judgment are now guiding lower courts in various tech scenarios, including cloud services and digital marketing, necessitating the tax department to adjust its approach in pending assessments.