Held that distribution agreement did not create any interest or right in assessee, which would amount to use of or right to use any copyright, said payment did not amount to royalty. Not taxable in India. Matter remanded. (AY. 2017-18)
Quest Software International Ltd. v. DCIT(IT) (2021) 191 ITD 243 (Bang.)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Payment to distributor-No right to use any copy right-Not taxable as royalty in India-Matter remanded.