Payment for Copyrighted Work on CD-ROM is a Goods Purchase, Not Royalty; TDS u/s 195 Not Applicable.

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....TDS u/s 195 - the assessee can not be said to have paid the consideration for use of or the right to use copyright but has simply purchased the copyrighted work embedded in the CD- ROM which can be said to be sale of ‘good’ by the owner. The consideration paid by the assessee thus as per the clauses of DTAA can not be said to be royalty - AT....