Held that sale of licence to use software could not be termed as royalty within provision of DTAA. Not liable to deduct tax at source. (AY. 2014-15)
IBM Singapore (Pte.) Ltd. v. DCIT (IT) (2021) 191 ITD 486 (Bang.)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of licence to use software-Not assessable as royalty-Not liable to deduct tax at source-DTAA-India-Singapore. [S. 9(1)(vii), 90(2), 195, Art. 12]