Double Taxation Avoidance Agreement Overrides Income Tax Act: No Tax on Software Licensing or Hardware Sales.

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Full Text of the Document

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....Royalty receipt - since the provisions of DTAA overrides the provisions of Income Tax Act and are more beneficial and the definition of ‘Royalty’ having not undergone any amendment in Tax Treaty, the assessee was not liable to be taxed on aforesaid receipts of Licensing software and also on sale of Hardware - AT....