Consideration received for licensing of software programmes- Royalty U/s. 9(1)(vi)/ Article 12

Since the definition given in Article 12(4) of the DTAA does not contain any consideration for the use or right to use in ‘computer programme’ or ‘software’, the same cannot be imported into it. Further, as discussed above also, the perusal of clauses of the Master Agreement demonstrate that the customer, viz. HLL has paid the consideration for ‘use of computer software’ and not

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