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    <description>Receipts from sale of standard software were held not to constitute royalty because no copyright rights were transferred; the Tribunal applied its earlier orders in the assessee&#039;s own case and found no change in the factual matrix. It also relied on the jurisdictional High Court&#039;s dismissal of the Revenue&#039;s appeals, which confirmed that no substantial question of law arose. On that basis, the software sale proceeds were assessable as business income under Article 7 of the Indo-Finland DTAA, and the addition treating them as royalty was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=345654</link>
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