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Software Sales in India Not Classified as Royalty u/s 9(1)(vi) and India-Sweden DTAA Article 12.
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....Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as well as Article 12 of the India-Sweden DTAA and that the sale of software products by the assessee to its Indian distributors for further sale to end users is not in the nature of transfer of “copyright” and therefore not taxable in the hands of the assessee as “royalty” - AT....