Software Products Sale not Taxable as Royalty under India-Singapore DTAA

Symantec Asia Pacific Pte Ltd Vs DCIT (ITAT Delhi)

Departmental authorities have accepted the factual position that the assessee does not have any Permanent Establishment (PE) in India. Thus, the issue which requires examination is whether the amount received by assessee towards sale of software products and provision of maintenance services would be taxable as royalty under Article 12 of India-Singapore DTAA. It is a fact on record that both the Assessing Officer as well as learned DRP have relied upon thei

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