Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of 'copyrighted article' and not towards the use of 'copyright' - it is not towards the use of or right to use any industrial, commercial or scientific equipment - where the end-user acquires only the right to run the programme and does not acquire any rights to use the copyright in the programme may not be construed as 'royalties'.
Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of 'copyrighted article' and not towards the use of 'copyright' - it is not towards the use of or right to use any industrial, commercial or scientific equipment - where the end-user acquires only the right to run the programme and does not acquire any rights to use the copyright in the programme may not be construed as 'royalties'.
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