Sale of Software Products does not Constitute Royalty Income, Not taxable under Article 12 of India- Japan DTAA: ITAT [Read Order]
Consideration received by the assessee from Indian end customers for sale of software products is not a royalty income and is not taxable under Article 12 of the India - Japan DTAA and also not business profits under Article 7 of the India Japan DTAA
In a recent ruling, the Delhi bench of the Income Tax Appellate Tribunal ( ITAT ) ruled that the sale of software products does not constitute royalty income and is not taxable under Article 12 of India- Japan Double Taxation Avoidance Agreement ( DTAA ). The assessee is a non-resident for the purposes of the…
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