Payment for Internal Use of Copyrighted Article Not a Royalty Under India-UK DTAA; No TDS Liability u/s 195.

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....TDS u/s 195 - Payment of royalty - disallowance u/s 40(a)(i) - What the appellant gets is only a copyrighted article to use the product for its internal business purpose and not any right in any copyright to exploit the same for commercial reasons so as to constitute the payment received in consideration thereof as royalty in terms of Article 13 of the India UK DTAA. - No TDS liability - AT....