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Sum paid for acquiring copyrighted software couldn't be taxed as royalty: ITAT

September 30, 2020[2020] 119 339 (Delhi - Trib.)

INTERNATIONAL TAXATION : Amount received by assessee, a US based company, from sale of copyrighted software products/licences was in nature of business income which in absence of assessee's PE of India, could not be brought to tax said amount was not as 'royalty' under article 12 of India-USA DTAA

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