Shrink-wrap software sales not taxable as royalty in India u/s 9(1)(iv); aligns with India-U.S. tax treaty.

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....Receipt on account of sale of Shrink-wrap software is not in the nature of royalty hence is not liable in India in view of the provision of section 9(1)(iv) of the Act as well as Article 12(3) of the Double Taxation Avoidance Agreement between India and U.S.A - AT....