ITAT rules payment for SAP system access not process royalty u/s 9(1)(vi), no income accrual in India.

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....Accrual of income in India - Royalty receipt - consideration received by the Assessee from CPI for the use of the SAP system - the ITAT is correct in holding that the payment made by CPI to the Assessee for accessing the SAP system does not amount to process royalty under Section 9(1)(vi) of the Act. - HC....