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Sum received by Canadian Co. for grant of licence to use technology for internal purpose only wasn't royalty

December 21, 2018[2018] 100 taxmann.com 265 (Delhi - Trib.)

IT/ILT: Where payment was made for CMG's membership by ONGC for non-exclusive and non-transferable licence to use technology only for internal business purpose, since there was neither sale nor licence of copyright in any kind of software or technology, such payment could not be held to be reckoned as royalty

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