Payments for sale of software taxable as ‘Royalty’ under Article 12 of the India-Japan tax treaty

Re Acclerys K K (AAR)-AAR held that payments received by a non-resident for sale of software to end users / customers, through an independent reseller is taxable as ‘Royalty’ under Article 12 of the India-Japan tax treaty (the tax treaty). The AAR relied on recent ruling in the case of Citrix Systems Asia Pacific Pty. Ltd (AAR/822 of 2009) and held that the amount paid

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