2023 (12) TMI 1382

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..... Indo-China DTAA - whether payments made by the assessee s customers to it constituted royalty, in respect of software supplied? - as confirmed by SC [ 2021 (7) TMI 1336 - SC ORDER] supplies made (of the software) enabled the use of the hardware sold. It was not disputed that without the software, hardware use was not possible. The mere fact that separate invoicing was done for purchase and other t .....

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