Software Sales Income Classified as Business Income, Not Royalty, u/s 91(vi); Non-Taxable in India Without Permanent Establishment.

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....Royalty u/s. 91 (vi) OR Business income - sale of software products/ licenses - the said amount received by the assessee is normal business income of the assessee on account of sale of copy righted products (licenses) and not taxable in India in the absence of permanent establishment.....