Taxpayer Software Payment Classified as Royalty u/s 9(1)(vi) of Income Tax Act and Indo-US DTAA Article 13(2).

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....The payment made by the assessee for acquisition of the software as well as right to use the key provided by the supplier for making necessary modification, alteration, amendments or changes which amounts to acquiring the right to use the copy right and therefore the payment will fall in the definition of royalty as defined u/s 9(1)(vi) as well as under Article 13(2) of Indo-US DTAA. - AT....