TMI BlogWhen the assessee supplies the software which is incorporated on a CD, it has supplied tangible property...When the assessee supplies the software which is incorporated on a CD, it has supplied tangible property and the payment made by the cellular operator for acquiring such property cannot be regarded as a payment by way of royalty u/s 9(1)(vi) - HC ..... X X X X Extracts X X X X X X X X Extracts X X X X
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