Allowing the appeal the Tribunal held that sale proceeds on account of distribution of computer software received by assessee did not amount to royalty for use of copyright in computer software, and same would not give rise to any income taxable in India. Not liable to deduct tax at source. (AY. 2017-18)
Autodesk Asia (P.) Ltd. v. ACIT(IT) (2021) 190 ITD 123 (Bang.)(Trib.)
S. 195 : Deduction at source-Non-resident-Other sums-Distribution of computer software-Ancillary services-Services rendered and amount received outside India-Not royalty-Not liable to deduct tax at source-DTAA-India-Singapore. [S. 9(1)(vi), Art, 12]