Supreme Court: Microsoft's software licenses in India not taxable as royalty u/s 9(1)(vi) and DTAA Article 12.

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....Income deemed to accrue or arise in India - licensing of software products of Microsoft in the Territory of India by the Respondent was not taxable in India as Royalty under Section 9(1)(vi) read with Article 12 of the Indo US DTAA - this is not Royalty liable to be taxed in India - Revenue appeal dismissed - SC....