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    <title>2012 (12) TMI 244 - ITAT BANGALORE</title>
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    <description>Imported shrink-wrapped software licence payments were treated as royalty because the licence conferred a right to use the software and to make installation and backup copies, which was viewed as involving copyright rights. On that basis, the consideration fell within section 9(1)(vi) of the Income-tax Act and the relevant DTAA, so tax was deductible at source under section 195. Failure to deduct justified consequential liability under sections 201(1) and 201(1A), and the additions and interest were upheld by following the jurisdictional High Court ruling in the assessee&#039;s own case and an earlier coordinate bench decision on identical facts.</description>
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