https://www.taxtmi.com/highlights?id=63562 Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of consideration for grant of software license is held not to be Royalty under the provisions of Income Tax Act, 1961, the question of consideration of the issue under the provisions as per DTAA between India and Netherland does not arise. Thus, ground of appeal No.1 filed by the assessee stands allowed. - AT en-us Thu, 19 May 2022 12:27:26 +0530 Thu, 19 May 2022 12:27:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=63562 Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of consideration for grant of software license is held not to be Royalty under the provisions of Income Tax Act, 1961, the question of consideration of the issue under the provisions as per DTAA between India and Netherland does not arise. Thus, ground of appeal No.1 filed by the assessee stands allowed. - AT Highlights Income Tax Thu, 19 May 2022 12:27:26 +0530 https://www.taxtmi.com/highlights?id=63562