Assessee not required to deduct TDS on software purchases pre-explanation 4 of Section 9(1)(vi) Income Tax Act.

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....Royalty - Existence of Permanent Establishment in India - TDS liability - software purchase - assessee during the relevant period prior to the insertion of explanation 4 to section 9(1)(vi) of the I.T. Act, was not liable to deduct TDS - AT....