Payments for Indian software distribution not classified as 'Royalty' income; DJCIPL lacks rights to reproduce or adapt software.

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....Royalty income - distributing its products the Indian market - there is no transfer of legal title in the copyrighted article as the same rests with the assessee. All rights, title and interest in the licensed software which is being claimed to be copyrighted article are the exclusive property of the assessee. DJCIPL has no authority to reproduce the date in any material form to make any translation in the date or to make adaptation in the data. - the payments received cannot be said to be ‘Royalty’ in nature. - AT....