Income deemed to accrue or arise in India

Brief: Income deemed to accrue or arise in India-Under section 9(1)(vi)-Income from supply of software to clients in India-Where assessee was engaged in sale of copyright software then income from such sale cannot be treated as royalty under section 9(1)(vi) particularly where assessee did not have any PE in India. Citation: (2010) 34 (II) ITCL 508 (Bang `B’ Trib) Velankani Mauritius Ltd. & Ors. v. Dy. DIT Counsel: Arvind Sonde, Advocate, for the Appellant q Smt. Preeti Garg, CIT, for the Respondent Court : ITAT Bangalore ORDER These two appeals are filed by the as...