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Payment to foreign Co. for outright purchase of software is not "royalty": ITAT

April 2, 2019[2019] 103 taxmann.com 399 (Delhi - Trib.)/[2019] 69 ITR(T) 247 (Delhi - Trib.)

IT/ILT: Where assessee, an Ireland based company, earned income from sale of software to its distributor in India, in view of fact that assessee received consideration for transfer of a copyrighted product and not for transfer of copyrights in computer software programme, amount received by assessee was not in nature of 'royalty' as defined under article 12 of India-Ireland DTAA

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