Sale Proceeds Not 'Royalty' Under Article 12 of India-Ireland DTAA; Involves Copyrighted Article, Not Copyright Rights.

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....Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of 'copyrighted article' and not towards the use of 'copyright' - it is not towards the use of or right to use any industrial, commercial or scientific equipment - where the end-user acquires only the right to run the programme and does not acquire any rights to use the copyright in the programme may not be construed as 'royalties'.....