Income Not Accrued in India: Software Trader's Royalty Receipts Exempt as No Copyright Transfer Occurred, Says CIT(A).

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....Income deemed to accrue or arise in India - Royalty receipt - The assessee is merely a trader of software, hence, has no domain or ownership over the software. Thus, when the assessee does not have any ownership over the softwares sold, it could not have transferred the right to use of copyright of the software to distributors/customers in India. - CIT(A) rightly deleted the additions - AT....