Section 195: No Withholding Tax Obligations if Payer Believes Licensed Software Royalties Aren't Taxable Income.

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....Withholding tax u/s 195 - Royalty u/s 9(1)(iv) - right to use the licensed version of the software - when the payer has a bona fide belief that the income is not chargeable to tax at all, there is no application of the section 195 at all and there is no liability on the payer to follow its provisions when making payment to non-residents.... - AT....