Intec-Ireland's Software Supply Receipts Not Taxable as Royalties Under New Ireland Tax Treaty; No Indian Taxation Due to No PE.

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....Taxability of supply of software - the receipts from supply of software are not taxable in the hands of Intec–Ireland as Royalty under new Ireland tax treaty. Intec-Ireland does not have PE in India and accordingly amounts received by Intec-Ireland towards supply of software are not liable to tax in India. - AT....