Held that amount of consideration received by Singapore based company, on account of sale of computer software to end users customers in India was not taxable as royalty for use of copyright in computer software. (AY. 2015-16)
ACIT v. Symantec Asia Pacific Pte. Ltd. (2022) 197 ITD 25 / (2023) 102 ITR 387 (Delhi)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of computer software-Not taxable as royalty-DTAA-India-Singapore. [S. 9(1)(vii), Art. 12(3)]