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Computer software licence payments fall within the royalty clarification only prospectively from 1 April 2012. Tax deducted on payments to foreign suppliers does not, by itself, establish taxability of comparable payments to domestic suppliers, which require independent examination; consequently, the stated software licence renewals attracted no tax-deduction disallowance. For tax-deduction disallowance, "payable" includes amounts already paid. One-time non-refundable membership fees are recognised over the membership period, supporting apportioned recognition rather than immediate treatment in full.
Computer software licence payments fall within the royalty clarification only prospectively from 1 April 2012. Tax deducted on payments to foreign suppliers does not, by itself, establish taxability of comparable payments to domestic suppliers, which require independent examination; consequently, the stated software licence renewals attracted no tax-deduction disallowance. For tax-deduction disallowance, "payable" includes amounts already paid. One-time non-refundable membership fees are recognised over the membership period, supporting apportioned recognition rather than immediate treatment in full.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
