TMI BlogIncome from software use not taxable in India if no actual usage right per agreement; DTAA applies.Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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