https://www.taxtmi.com/highlights?id=46347 Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of 'copyrighted article' and not towards the use of 'copyright' - it is not towards the use of or right to use any industrial, commercial or scientific equipment - where the end-user acquires only the right to run the programme and does not acquire any rights to use the copyright in the programme may not be construed as 'royalties'. en-us Wed, 08 May 2019 07:23:51 +0530 Wed, 08 May 2019 07:23:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=46347 Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of 'copyrighted article' and not towards the use of 'copyright' - it is not towards the use of or right to use any industrial, commercial or scientific equipment - where the end-user acquires only the right to run the programme and does not acquire any rights to use the copyright in the programme may not be construed as 'royalties'. Highlights Income Tax Wed, 08 May 2019 07:23:51 +0530 https://www.taxtmi.com/highlights?id=46347