Software Sale Payments Classified as 'Royalty' u/s 195 of Income Tax Act Due to Copyright Transfer Rights.

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....Sale of Software – Royalty – TDS u/s. 195 - the right that is transferred in the present case is the transfer of copyright including the right to make copy of software for internal business, and payment made in that regard would constitute 'royalty' for imparting of any information concerning technical, industrial, commercial or scientific knowledge, experience or skill as per clause (iv) of Explanation 2 to Section 9(1)(vi). - AT....