such royalties, no doubt in the context of technical
services, and remittances for supply of computer software,
which is then treated as business profits, taxable ... provision of managerial, technical or consultancy
services. This is clearly evident from Article 12 (4) using the
expression "if such services....". However, once
such royalties, no doubt in the
context of technical services, and remittances for supply of computer
software, which is then treated as business profits, taxable ... that the payment received by EYGSL (UK) for providing access
to computer software to its member firms of EY Network located in
India, that
such royalties, no doubt in
the context of technical services, and remittances for supply of
computer software, which is then treated as business profits,
taxable ... same pertains to payments received as consideration for
managerial, technical or consultancy services and which are
ancillary or subsidiary to enjoyment of the right, property
such royalties,
no doubt in the context of technical services, and remittances
for supply of computer software, which is then treated as
business profits, taxable ... same pertains to payments received as
consideration for managerial, technical or consultancy
services and which are ancillary or subsidiary to enjoyment
of the right, property
such royalties, no doubt in
the context of technical services, and remittances for supply of
computer software, which is then treated as business profits,
taxable ... same pertains to payments received as consideration for
managerial, technical or consultancy services and which are
ancillary or subsidiary to enjoyment of the right, property
M/S. Idea Cellular Limited, Indore vs The Dcit (Tds), Indore on 1 August, 2024
providing technical services or in the nature of freight,
telecommunication charges or insurance attributable to delivery of article
or things or computer software, from
providing technical services or in the nature of freight,
telecommunication charges or insurance attributable to delivery of article
or things or computer software, from
M/S. Idea Cellular Limited, Indore vs The Dcit (Tds), Indore on 1 August, 2024
providing technical services or in the nature of freight,
telecommunication charges or insurance attributable to delivery of article
or things or computer software, from
