Consideration for right to use copy right shrink-wrap software amounts to royalty

Brief facts of the case are that the assessee is an Indian Company who is engaged in developing telecommunication During the relevant asst. year, the assessee has purchased shrink-wrap Software from Cadence Designs Ireland amounting to Rs.5,946,245/- and Rs.4,015,887/- respectively. The AO noticed that the assessee has remitted the above amounts to Cadence Designs Systems Ireland without deducting tax at source u/s 195 of the Income-tax Act 1961. The AO initiated proceedings u/s 20 1(1) and issued show cause notice dated 25/12/2011 why the assessee sh

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