Payments for Software Not "Royalty" Under DTAA, No Tax Deduction Required u/s 195 of Income Tax Act.

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....TDS u/s 195 - royalty - purchase of software - copyrighted articles - payments made by it to various suppliers of six countries did not amount to royalty within the definition of Article 12/13(3) of the DTAA and it was not obliged to deduct tax at source - AT....