Royalty exclusion for lump-sum transfers of computer software supplied with equipment clarifies tax treatment under the clause. The amendment excludes from the clause any portion of royalty that consists of a lumpsum payment made by a resident for transfer of all or any rights (including the granting of a licence) in respect of computer software supplied by a non-resident manufacturer along with a computer or computer-based equipment under any scheme approved under the Policy on Computer Software Export, Software Development and Training, 1986 of the Government of India.
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Provisions expressly mentioned in the judgment/order text.
Royalty exclusion for lump-sum transfers of computer software supplied with equipment clarifies tax treatment under the clause.
The amendment excludes from the clause any portion of royalty that consists of a lumpsum payment made by a resident for transfer of all or any rights (including the granting of a licence) in respect of computer software supplied by a non-resident manufacturer along with a computer or computer-based equipment under any scheme approved under the Policy on Computer Software Export, Software Development and Training, 1986 of the Government of India.
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