Software Payments Not Classified as Royalty Income, No Permanent Establishment in India Supports Non-Taxability.

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....Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.....