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Income Tax - Highlights / Catch Notes

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Royalty - The source code embedded in the software has not been ...

Income Tax

April 18, 2017

Royalty - The source code embedded in the software has not been imparted to them - for all the years the payments received by the assessee from WIPRO/IBM in pursuance to the MSA cannot be treated as “royalty” under Article 12(4) of the India-Netherland DTAA - AT

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  10. IT Computer software after being put on to a media and then sold, becomes goods like any other Audio Cassette or painting, payment cannot be termed as Royalty

 

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