2024 (9) TMI 879

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..... ondent - TDS u/s 195 - whether taxable in India as Royalty u/s 9(1)(vi) of the Act read with Article 12 of the Indo US DTAA? As decided by HC [ 2022 (3) TMI 482 - DELHI HIGH COURT] amounts paid by resident Indian end-users/distributors to nonresident computer software manufacturers/suppliers, as consideration for the resale/use of the computer software through EULAs/distribution agreements, is not .....

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