Software Sale Payments Not "Royalty" Under Article 12(4) of Indo-Netherland DTAA; Not Taxable in India.

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....Taxability of sale of software as “Royalty” - payment received by the assessee for sums does not amount to “royalty” within the meaning of Article 12(4) of Indo-Netherland DTAA and accordingly, the same is not taxable in India. - AT....