Payment received on account of supply of software products to independent third party re-sellers in India not royalties but business income

The applicant is a company incorporated in Japan and is engaged in the business of providing Products Lifecycle Management software solutions, applications and services. These software products are standardised and not customised or tailor-made. It markets its products in India through a distribution channel of third party re sellers comprising Value Added Re sellers (VAR) who resells the software to end-users.

The product is sold by the applicant to VAR at standard list price less discount. The VAR sells the

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