Royalty receipt - Receipts towards access to use software - ...

Payments from WIPRO/IBM under MSA not "royalty" per Article 12(4) of India-Netherlands DTAA for all years.

January 17, 2020

Case Laws Income Tax AT

Royalty receipt - Receipts towards access to use software - India– Netherlands DTAA - For all the years the payments received by the assessee from WIPRO/IBM in pursuance to the MSA cannot be treated as “royalty” under Article 12(4) of the India-Netherland DTAA.

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Royalty receipt - Receipts towards access to use software - ...

Payments from WIPRO/IBM under MSA not "royalty" per Article 12(4) of India-Netherlands DTAA for all years.

January 17, 2020

Case Laws Income Tax AT

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