TDS on software payment

An Indian company  pays to a Singapore company license fees for purchase of software which is loaded on to chips procured from outside India.  The embedded chip is used in SIM card  which is sold to various institutions.  The relevant portion of  software license agreement  with   Singapore co is  re produced below: License Grant 1) Against Payment Of the associated license fee, the  xx Singapore  company   hereby grant the Licensee a non-exclusive (save as may be stated to the contrary in Annex E) and non-transferable license to use the xxxxx  Product Software and Documentation or any portion thereof  to manufacture…

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