Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Supply of software on licence - Taxability in India - If the receipts cannot be taxed under the treaty as royalty, then it cannot be taxed under the domestic law under section 9(1)(vi) Income Tax Act and the amended provision cannot be read into treaty - AT
Supply of software on licence - Taxability in India - If the receipts cannot be taxed under the treaty as royalty, then it cannot be taxed under the domestic law under section 9(1)(vi) Income Tax Act and the amended provision cannot be read into treaty - AT
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