High Court Rules 'Off the Shelf' Software Sales Not a Royalty, Income Not Taxable Under Indian Law.

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....Income deemed to accrue or arise in India - Royalty receipt - there was no transfer of copyright in the ‘off the shelf’ sale software; the consideration received thereby could not be construed as royalty and hence was not taxable - the Tribunal was right in concluding, that the consideration received by the respondent/assessee, did not constitute royalty - HC....