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    <title>2012 (10) TMI 980 - ITAT BANGALORE</title>
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    <description>Consideration for shrink-wrapped software licences was treated as royalty where the licence transferred only a restricted right to use copyright-protected software, including restrictions on copying, alteration, reverse engineering, sublicensing, rental and further distribution. On that basis, the royalty issue was decided against the assessee. The Tribunal also held that interest under section 234B was not leviable on a non-resident where the relevant tax was deductible at source by the payer under section 195 and had to be excluded from advance-tax computation. That issue was decided in favour of the assessee.</description>
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