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Taxpayer's Software Payment to ASL Not a Royalty; No TDS Liability u/s 195 Due to No PE in India.

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....TDS u/s 195 - the opinion that payment by the assessee to ASL for procuring and distributing copyrighted software on principal to principal basis could not be treated as payment towards royalty.ASL was not having a PE in India - No TDS liability....

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