Court Rules Software Payments to Indian PE Not Royalties Under DTAA; Separate Invoicing Irrelevant to Classification.

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....Taxability of amount received - PE in India - DTAA - whether payments made by the assessee’s customers to it constituted royalty, in respect of software supplied? - supply of software, in the nature of articles or goods. - The mere fact that separate invoicing was done for purchase and other transactions did not imply that it was royalty payment - HC....