TDS not deductible on Software Purchased with mere ‘right to use’ 

the payment made for the use of copyrighted article was not royalty. The definition of ‘royalty’ under DTAA had not been amended though there is retrospective amendment to section 9(1)(vi) of the Act but since the provisions which are more beneficial to the assessee are to be applied, then as per un-amended provisions of royalty under DTAA, the assessee having purchased copyrighted article and not having purchased copyrigh

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