Red Hat Subscription Payments Not Royalties; No TDS u/s 195, Per India-Singapore DTAA Article 12(3).

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....TDS u/s 195 - Royalty - import of software - The payments in question is made by the user of the Red Hat Subscriptions for the purpose of availing convenient installation, ongoing maintenance and support services provided by Red Hat engineers to the users of Red Hat Subscriptions and not towards Red Hat software. Thus, the payment does not towards sale of software which is freely available in the public domain. Therefore, in terms of Article 12(3) of India- Singapore DTAA it is not recognized royalty. - AT....