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Payment for transfer of use of right to use software, not royalty as per Indo-Belgium DTAA

February 18, 2020[2020] 114 taxmann.com 89 (Mumbai - Trib.)
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INTERNATIONAL TAXATION: Introduction of Explanation 4 to section 9(1)(vi) with retrospective effect would make payment for transfer of use or right to use computer a royalty; however, in absence of corresponding amendment in Indo-Belgium DTAA, such payment could not be treated as royalty liable to tax

INTERNATIONAL TAXATION: Where software was inseparable part of imaging equipments/MRI machines sold, payment made to foreign AE on purchase of software would not be in nature of royalty

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