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DTAA royalty definition

  • TDS on Purchase of Software from Outside India u/s 195

    • July 6, 2025
    • Posted by: Amit Mundhra CA
    • Category: Income Tax Cases
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    The Supreme Court in the Engineering Analysis case ruled that payments for software purchases without transfer of copyright are not ‘royalty’ and hence not subject to TDS under Section 195. This landmark decision brings clarity on TDS applicability for software, cloud services, and cross-border transactions.

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