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14. TS-605-ITAT-2016(HYD) Qualcomm India Private Limited vs. ADIT A.Y.s: 2006-07 to 2009-10, Date of Order: 28th October, 2016

GEETA JANI
DHISHAT B. MEHTA
Chartered Accountants

Section 9(1)(vi) of the Act – (i) End user software license package was a copyrighted article, not license to use the copyright – payment was not royalty – consequently, payment for ‘support services’ was also not royalty; (ii) Payment was for internet and bandwidth services provided by service provider – sophisticated equipment installed by service provider for providing service – service recipient did not have exclusive right to use such equipment – payment was not royalty