UK Software Payments to India Not Taxable as Royalty, Says High Court; Overturns AAR Ruling Under Income Tax Act.

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....Income accrued in India - royalty receipts - transfer of copyright in the software - India-UK DTAA - The Impugned Rulings passed by the learned AAR are set aside and it is held that the payment received by EYGSL (UK) for providing access to computer software to its member firms of EY Network located in India, that is, EYGBS (India), does not amount to “royalty” liable to be taxed in India under the provisions of the Income Tax Act, 1961 and the India-UK DTAA. - HC....