Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.
Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.
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