License Fees Not Classified as 'Royalty' Under India-Canada DTAA; No Tax for Non-Resident Company.

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....Accrual of Income in India - assessee as a non-resident company which received licence fees in terms of "Membership and Technology Transfer Agreement" - the receipt cannot be characterized as ‘royalty’ and, therefore, the same is outside the purview of taxation in view of India-Canada DTAA.....