Income deemed to accrue or arise in India - “If Royalty is payable by” - Section 9(1)(vi)

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..... e following Where it is payable in respect of any right, property or information used or services utilised for the purposes of a business or profession carried on by such person outside India or For the purposes of making or earning any income from any source outside India; or a person who is a non-resident , for the purpose of Where it is payable in respect of any righ .....

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..... d electronic data; If transfer of property is already taxable under the Capital Gain, then it is not covered under the definition of Royalty . Consideration for use or right to use of computer software is covered under Royalty. 5. Meaning of Royalty - Royalty means consideration (including any lump sum consideration but excluding any consideration which would be the income of the r .....

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..... ounts referred to in section 44BB ; ( v ) the transfer of all or any rights (including the granting of a licence) in respect of any copyright, literary, artistic or scientific work including films or video tapes for use in connection with television or tapes for use in connection with radio broadcasting; or ( vi ) the rendering of any services in connection with the activities referred to i .....

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