Software Sale Receipts Not Taxed as Royalty Income u/s 9(1)(vi) and India-Ireland DTAA Article 12.

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....Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty provisions are more beneficial, an adjudication on nature of receipts vis a vis provisions of Section 9(1)(vi) is not required.....