Licensing of software products of Microsoft in India not taxable as Royalty

CIT (International Taxation) Vs Gracemac Corporation  (Delhi High Court)

High court held that licensing of software products of Microsoft in the Territory of India by the Respondent was not taxable in India as Royalty under Section 9(1)(vi) of the Act read with Article 12 of the Indo US DTAA.

FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT

1. Present appeals have been filed under Section 260A of the Incom

Please become a Premium member. If you are already a Premium member, login here to access the full content.