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Amount received towards supply of software embedded in hardware did not amount to ‘royalty’ under section 9(1)(vi)

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  • Amount received towards supply of software embedded in hardware did not amount to ‘royalty’ under section 9(1)(vi)
Posted onon June 19, 2015

Tenet Tax Daily June 15 2015

By tenettax-team
Corporate Tax, International Tax

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High Court critical of ITAT for passing order on basis of docs and evidences not presented before AO or CIT(A)
Reimbursement of debtor collection charges to US based by assessee who had made direct payment to payee would not fall within ambit of ‘fee for technical services’ and assessee was not required to deduct tax at source while making payment in question

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