2014 (9) TMI 1063

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..... conditions stipulated in the DTAA have to be satisfied. The question raised, it is accepted, is covered by the decision of this Court in DIT Vs. Infrasoft Limited [2013 (11) TMI 1382 - DELHI HIGH COURT ] wherein held that the right to make a backup copy purely as a temporary protection against loss, destruction or damage does not amount to acquiring a copyright in the software - What has been tran .....

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..... t taxable as business income. In the present case, Double Taxation Avoidance Agreement between India and the United States of America is applicable and to construe royalty conditions stipulated in the DTAA have to be satisfied. The question raised, it is accepted, is covered by the decision of this Court in ITA 1034/2009, DIT Vs. Infrasoft Limited decided on 22nd November, 2013. In view of the .....

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