Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Income deemed to accrue or arise in India - Royalty receipt - Voice Interconnect Services (IUC) - the installation and operation of sophisticated equipments are with the view to earn income by allowing the users to avail the benefits of such equipments or facility and does not tantamount to granting the use or the right to use the equipment or process so as to be considered as royalty within the definition of “royalty” as contained in clause 3 of Article 13 of India-Austria DTAA. - AT
Income deemed to accrue or arise in India - Royalty receipt - Voice Interconnect Services (IUC) - the installation and operation of sophisticated equipments are with the view to earn income by allowing the users to avail the benefits of such equipments or facility and does not tantamount to granting the use or the right to use the equipment or process so as to be considered as royalty within the definition of “royalty” as contained in clause 3 of Article 13 of India-Austria DTAA. - AT
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