US-India DTAA: Payments for Software Classified as Royalty, Not Taxable to Avoid Double Taxation on Assessee.

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....DTAA between US & India - Royalty or sale of copyrighted articles / softwares - though the amount constitute royalty, but the same is not assessable in the hands of the present assessee. - such royalty cannot be assessed in the hands of the assessee as it will tantamount to assess the same income which has been assessed in the hands of Gracemac - AT....