TDS on Software Payments: Domestic Law Amendments Can't Alter 'Royalty' Definition in DTAA u/s 195.

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....TDS u/s 195 - payment for software - the ‘royalty’ has been specifically defined in the treaty and amendment to the definition of such term under the Act would not have any bearing on the definition of such term in the context of DTAA. A treaty which has entered between the two sovereign nations, then one country cannot unilaterally alter its provision - AT....