Software License Sales to Indian Customers Not Taxable as Royalty or Business Profits Under India-Japan DTAA.

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....Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee from Indian end customers for sale of software products does not constitute royalty income and is not taxable under Article 12 of the India-Japan DTAA and is not business profits under Article 7 of the India Japan DTAA - The ITAT dismissed the appeals of the Revenue, upholding the CIT(A)'s decision to delete the addition made by the AO.....