| COURT: | ITAT Hyderabad |
| CORAM: | Asha Vijayaraghavan (JM), Chandra Poojari (AM) |
| SECTION(S): | 9(1)(vi), Article 12 |
| GENRE: | International Tax |
| CATCH WORDS: | royalty, software licensing |
| COUNSEL: | P. Murali Mohan Rao |
| DATE: | January 27, 2014 (Date of pronouncement) |
| DATE: | November 29, 2014 (Date of publication) |
| AY: | 2009-10 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| Consideration for use of software is not assessable as royalty under Article 12 of DTAA and s. 9(1)(vi) | |
(i) In order to qualify as royalty payment, it is necessary to establish that there is transfer of all or any rights (including the granting of any licence) in respect of copyright of a literary, artistic or scientific work. In …
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