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TMI BlogTDS u/s 195 - Royalty - amounts paid by the concerned persons resident in India to non-resident, foreign...TDS u/s 195 - Royalty - amounts paid by the concerned persons resident in India to non-resident, foreign software suppliers - Given the definition of royalties contained in Article 12 of the DTAAs it is clear that there is no obligation on the persons mentioned in section 195 of the Income Tax Act to deduct tax at source, as the distribution agreements/EULAs in the facts of these cases do not create any interest or right in such distributors/end-users, which would amount to the use of or right t..... ..... X X X X Extracts X X X X X X X X Extracts X X X X
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