Licensing of Software Products of “Microsoft” in India by “HP Services” is not Taxable in India as Royalty u/s 9(1)(vi) and Article 12 of Indo US DTAA: ITAT [Read Order]

By Sunayana Dhal - On October 19, 2023 2:56 pm - 2 mins read
Licensing of Software Products - Software Products - Microsoft India - HP Services - ITAT - taxscan

The Delhi bench of the Income Tax Appellate Tribunal (ITAT) held that the licensing of the software products of Microsoft in India by HP Services is not taxable in India as royalty under Section 9(1)(vi) of the Income Tax Act, 1961 and Article 12 of Indo US DTAA. The issue was with respect to the…

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