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Income from sale of software license & support maintenance services in India not taxable as royalty: ITAT

September 14, 2021[2021] 130 taxmann.com 205 (Pune - Trib.)
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INTERNATIONAL TAXATION : Income earned by assessee company from sale of software licenses and income from support, maintenance and training services rendered in relation to such software licenses sold either directly or indirectly through third parties in India was not chargeable to tax as "Royalty" under section 9 as well as under article 12 of DTAA between India and Singapore; same would be in nature of business income, however, since assessee did not have PE in India, such income ceased to be taxable in India

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