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    <description>The court ruled in favor of the revenue and against the assessee, finding that the payments made for the purchase of software constituted &#039;royalty&#039; and were taxable in India. It was held that the resident payer had an obligation under section 195 of the Income-tax Act, 1961, to deduct tax at source. The appellate authority&#039;s assessment of the non-resident&#039;s income in the hands of the resident payer was deemed beyond the scope of section 195. The court allowed the appeals and appreciated the counsels&#039; assistance in interpreting the legal provisions.</description>
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      <link>https://www.taxtmi.com/caselaws?id=178418</link>
      <description>The court ruled in favor of the revenue and against the assessee, finding that the payments made for the purchase of software constituted &#039;royalty&#039; and were taxable in India. It was held that the resident payer had an obligation under section 195 of the Income-tax Act, 1961, to deduct tax at source. The appellate authority&#039;s assessment of the non-resident&#039;s income in the hands of the resident payer was deemed beyond the scope of section 195. The court allowed the appeals and appreciated the counsels&#039; assistance in interpreting the legal provisions.</description>
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