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Income Tax - Highlights / Catch Notes

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TDS u/s 195 - Payments for software licenses fees as 'Royalty' ...


Software License Fees as 'Royalty' u/s 9(1)(vi) Can't Override DTAA Definition; Impacts TDS u/s 195.

April 10, 2018

Case Laws     Income Tax     AT

TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of amendment to section 9(1)(vi) of the Act cannot be extended to the meaning of the term ‘royalty’ defined under DTAA. - AT

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