https://www.taxtmi.com/caselaws?id=119047 The Tribunal concluded that payments for imported software do not constitute royalty under section 9(1)(vi) of the Act, as they are characterized as purchase and sale of goods. With no permanent establishment in India, no income accrues in India, rendering section 195 inapplicable. The Tribunal set aside the order under section 201(1) and interest under section 201(1A), allowing the appeals. en-us Thu, 28 Apr 2005 00:00:00 +0530 Mon, 06 May 2024 12:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=119047 The Tribunal concluded that payments for imported software do not constitute royalty under section 9(1)(vi) of the Act, as they are characterized as purchase and sale of goods. With no permanent establishment in India, no income accrues in India, rendering section 195 inapplicable. The Tribunal set aside the order under section 201(1) and interest under section 201(1A), allowing the appeals. Case-Laws Income Tax Thu, 28 Apr 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=119047