The ITAT Delhi held that receipts from software licensing were not taxable as royalty under the India–USA DTAA and, in the absence of a Permanent Establishment in India, were not chargeable to tax as business profits.
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The ITAT Delhi held that receipts from software licensing were not taxable as royalty under the India–USA DTAA and, in the absence of a Permanent Establishment in India, were not chargeable to tax as business profits.
