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of The SC dismissed the SLP, affirming the HC and ITAT rulings that the consideration received by the assessee, a Singapore tax resident, from licensing Customer Relationship Management software to various customers does not constitute royalty income under Article 12(3) of the India-Singapore DTAA. Consequently, such receipts are not deemed to accrue or arise in India for tax purposes. The decision upholds the lower authorities' interpretation, providing relief to the assessee by excluding the licensing fees from the ambit of taxable royalty income under the treaty.
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