Payments Under Master Services Agreement Not "Royalty" Per India-Netherlands DTAA Article 12(4) Due to No Source Code Transfer.

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....Royalty - The source code embedded in the software has not been imparted to them - for all the years the payments received by the assessee from WIPRO/IBM in pursuance to the MSA cannot be treated as “royalty” under Article 12(4) of the India-Netherland DTAA - AT....