Guide To Transfer Pricing Law In India
Guide to transfer pricing law in India with methods of determining ALP, APA scheme, documentation procedures, Landmark cases and latest judgements on transfer pricing controversies
January 2018
Taxability of off the shelf software as ‘Royalty’ under the income-tax Act and DTAA
In this article we will consider whether the amounts received on account of supply of off the shelf software can be taxed as ‘royalty’ under Section 9(l)(vi) of the Act and Article 12 of the Double Taxation Avoidance Agreement between India and Ireland (‘India- Ireland Tax Treaty)