Income accrued in India - royalty receipts - what is sold is the ...
Case Laws Income Tax
September 27, 2023
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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