Payment for copyrighted software to parent company not royalty u/s 9(1)(vi), no TDS deduction u/s 195 required.
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....TDS u/s 195 - copyrighted software products - payment made by the assessee to its parent company for purchase of copyrighted software to be distributed in India for end users cannot be considered as royalty as defined u/s 9(1)(vi) consequently, the assessee is not required to deduct TDS u/s 195 - hence, no disallowance u/s 40(a)(ia)....


TaxTMI
TaxTMI