Software Maintenance, Consulting, and Training Fees Classified Like License Fees; Not FTS Per Article 12, Clause 5.

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....Accrual of income in India - Royalty / FTS - the software maintenance fees, consulting charges and training fees which are incidental to software license fee, assumes same character as that of software license fee - Even the software maintenance, consulting charges and training fees which are incidental to software maintenance fee cannot come within the purview of FTS within clause 5 of Article 12 of the treaty - AT....