Software Sales Payments Classified as Royalties; TDS Deduction Required Under IT Act Section 9(1)(vi) and DTAA Article 12.

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....The payments received by the applicant from the distributor for sale of the software product are in the nature of royalty both within the meaning of section 9(1)(vi) of the IT Act and within the meaning of Article 12 of the DTAA - TDS required to be deducted u/s 195 - AAR....