TDS u/s 195 - the payment in question was consideration for the ...

Shrink-wrap software payments classified as royalties u/s 9(1)(vi) and Article 12 of Indo-Ireland DTAA; tax deduction required.

November 20, 2015

Case Laws Income Tax AT

TDS u/s 195 - the payment in question was consideration for the right to use copy right shrink-wrap software amounts to royalty within the meaning of sec. 9(1)(vi) of the Act and also Art 12 of the Indo- Ireland DTAA - it is clear that there is obligation to deduct tax at source u/s 195 - AT

View Source

← Previous Next →

TDS u/s 195 - the payment in question was consideration for the ...

Shrink-wrap software payments classified as royalties u/s 9(1)(vi) and Article 12 of Indo-Ireland DTAA; tax deduction required.

November 20, 2015

Case Laws Income Tax AT

You may also like:

TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

TDS u/s 195 - whether the payments made for acquiring the shrink-wrap Software amounts to royalty u/s 9(1)(vi) and also Indo-Ireland DTAA and, therefore, tax at source...

The assessee, a non-resident company incorporated in Singapore without a permanent establishment in India, received income from licensing of software to M/s. L&T Ltd....

Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty...

Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

Receipt on account of sale of Shrink-wrap software is not in the nature of royalty hence is not liable in India in view of the provision of section 9(1)(iv) of the Act...

Income deemed to accrue or arise in India - licensing of software products of Microsoft in the Territory of India by the Respondent was not taxable in India as Royalty...

TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of...

Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

Income taxable in India - Royalty u/s. 9 and/or under Article- 12 of India - payments made in terms of Sponsorship Agreement - Singapore, DTAA - sponsorship of the ICC...

Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as...

The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment...

TDS u/s 195 - payment for time charter higher charges are Royalty u/s 9(1)(vi) - The Tribunal held that the payments made by Jaisu Shipping Co. Pvt. Ltd. for hiring...

The payment made by the assessee for acquisition of the software as well as right to use the key provided by the supplier for making necessary modification, alteration,...

Quick Updates: