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    <title>2021 (7) TMI 608 - ITAT BANGALORE</title>
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    <description>Amounts paid for software licences and resale or use of computer software were held not to constitute royalty in India because the underlying agreements did not transfer any interest in copyright or any right to reproduce the software. A mere licence to use software, subject to restrictions on copying, modification, sublicensing and reverse engineering, was treated as consideration for the software as a product rather than payment for use of copyright. As a result, the receipts were not chargeable as royalty and no obligation to deduct tax at source arose under the charging and withholding provisions.</description>
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