Right to make copy of software would constitute ‘Royalty’ TDS deductible u/s 195

Prolific Research Pvt. Ltd Vs DCIT (ITAT Ahmedabad) ITAT Ahmedabad held that the transfer of copyright including the right to make copy of software for international business, any payment made in that regard would constitute ‘Royalty’. Thus, TDS is deductible u/s 195 on the payment made by the assessee to the non-resident supplier. Facts- The assessee is a company is engaged in the business of collecting market research data and conducting surveys/interviews in the different countries based on project specifications provided by its clients. In consideration, it receives payments on Cost Pe...