Shrink-wrap software payments classified as royalties u/s 9(1)(vi) and Article 12 of Indo-Ireland DTAA; tax deduction required.

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....TDS u/s 195 - the payment in question was consideration for the right to use copy right shrink-wrap software amounts to royalty within the meaning of sec. 9(1)(vi) of the Act and also Art 12 of the Indo- Ireland DTAA - it is clear that there is obligation to deduct tax at source u/s 195 - AT....