https://www.taxtmi.com/highlights?id=79926 TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12 of India-UK Tax Treaty. As per AO, tax required to be withheld as payments chargeable u/s.9(1)(vi) r.w.s. 195 read with DTAA Articles. Assessee stated payment for use of standard software, without obtaining rights for creation, modification or adaptation. HELD: Based on royalties definition in DTAA Article-13, payments not royalties. EULAs do not create interest/right in distributors/end-users amounting to use of or right to use copyright. No obligation u/s 195 to deduct TDS. Provisions of s.9(1)(vi) and explanations, not more beneficial than DTAA, not applicable. Amounts p..... en-us Wed, 31 Jul 2024 08:36:35 +0530 Wed, 31 Jul 2024 08:36:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=79926 TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12 of India-UK Tax Treaty. As per AO, tax required to be withheld as payments chargeable u/s.9(1)(vi) r.w.s. 195 read with DTAA Articles. Assessee stated payment for use of standard software, without obtaining rights for creation, modification or adaptation. HELD: Based on royalties definition in DTAA Article-13, payments not royalties. EULAs do not create interest/right in distributors/end-users amounting to use of or right to use copyright. No obligation u/s 195 to deduct TDS. Provisions of s.9(1)(vi) and explanations, not more beneficial than DTAA, not applicable. Amounts p..... Highlights Income Tax Wed, 31 Jul 2024 08:36:35 +0530 https://www.taxtmi.com/highlights?id=79926