2023 (6) TMI 1442

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..... ome from sale of shrink-wrapped software is taxable in India, being in the nature of royalty under the provisions of section 9(1)(vi) as well as Article 12(3) of the DTAA between India and USA - HELD THAT:- The issue in this appeal is squarely covered by the judgment in Engineering Analysis Centre of Excellence Private Limited [ 2021 (3) TMI 138 - SUPREME COURT] . Nagraj submits that there is a re .....

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