Sale of Software Licenses not constitutes Royalty

BMC Software Asia Pacific Pte Ltd. Vs ACIT (International Tax) (ITAT Pune)

Facts of the case:

♦ The assessee is a Singapore based company, which has not filed its Income Tax Return for the AY 2010-11. However, the assessee company has earned income from sale of Software Licenses and income from Support, Maintenance and Training services during the year under consideration.

♦ The Assessing officer “AO” has initiated re-asse

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