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Non-exclusive non-transferable computer software licence with no right to sub-lease qualifies as royalty income

February 17, 2020[2020] 113 592 (Chennai - Trib.)

INTERNATIONAL TAXATION: Grant of non-exclusive non-transferable license in computer software with no right to sub-lease or transfer would fall within purview of 'Royalty' both under India Italy DTAA as well as under section 9(1)(vi) and would be chargeable to income-tax under provisions of Act

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