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Income deemed to accrue or arise in India - Royalty receipt - there was no transfer of copyright in the...

Income deemed to accrue or arise in India - Royalty receipt - there was no transfer of copyright in the ‘off the shelf’ sale software; the consideration received thereby could not be construed as royalty and hence was not taxable - the Tribunal was right in concluding, that the consideration received by the respondent/assessee, did not constitute royalty - HC .....

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