Sale of software cannot be treated as royalty under India-Singapore DTAA

Microstrategy Singapore Pte. Ltd. Vs ACIT (ITAT Delhi)

Sale of software, a copyrighted article, cannot be treated as royalty under article 12(3) of India-Singapore DTAA

Facts- The assessee is a non-resident company incorporated in Singapore and is a tax resident of that country. The core activity of the assessee is distribution and maintenance of software to customers in the Asian market. Additionally, the assessee also offers consultancy, system integration and education services to its customers for

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