TDS not deductible on Amounts paid to non-resident manufacturers for resale/use of computer software

Altisource Business Solutions Private Limited Vs ACIT (ITAT Bangalore)

Amounts paid by the assessee to the non-resident computer software manufacturers / suppliers as consideration for the resale / use of computer software, is not payment of royalty for use of copyright in the computer software. Hence, the consideration paid to non-resident software manufactures / suppliers does not give rise to income taxable in India and was not liable for deduction of tax at source u/s 195 of the I.T.Act. It is ordered ac

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