Supreme Court rules software sales not considered royalty; not taxable u/s 9(1)(vi) or India-Israel DTAA.

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....Income chargeable to tax in India - Amount received by the Assessee for sale of software amounted to royalty as defined under Explanation 2 to Section 9(1)(vi) of the Income-tax Act, 1961 and under Section 12 of the India-Israel (DTAA) - Following the decision of Apex court that, the activity is not taxable in India - HC....