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Consideration for supplying standard software to Indian customers, directly or through an Indian subsidiary, is characterised under the India-USA DTAA as business income rather than royalty where the relevant facts, transaction terms, and legal position remain unchanged. In the absence of a permanent establishment in India, Article 7 prevents taxation of that business income in India. The corresponding addition that treated the software receipts as royalty is deleted.
Consideration for supplying standard software to Indian customers, directly or through an Indian subsidiary, is characterised under the India-USA DTAA as business income rather than royalty where the relevant facts, transaction terms, and legal position remain unchanged. In the absence of a permanent establishment in India, Article 7 prevents taxation of that business income in India. The corresponding addition that treated the software receipts as royalty is deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
