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Income Tax - Highlights / Catch Notes

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Income accrued in India - royalty receipts - what is sold is the ...


India-UK Tax Treaty: Off-the-shelf Software Sales to Distributors Not Royalty, No Taxation on Transactions in India.

September 27, 2023

Case Laws     Income Tax     HC

Income accrued in India - royalty receipts - what is sold is the copyrighted software which is shrink-wrapped - the consideration received on the sale of off-the-shelf, shrink-wrapped software to Indian distributors and resellers would not constitute royalty in terms of the India-UK Double Taxation Avoidance Agreement. - no substantial question of law arises - HC

 

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