Software License Fees as 'Royalty' u/s 9(1)(vi) Can't Override DTAA Definition; Impacts TDS u/s 195.

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....TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of amendment to section 9(1)(vi) of the Act cannot be extended to the meaning of the term ‘royalty’ defined under DTAA. - AT....