Friends, Consideration for use of right to use of computer software is royalty and therefore, such income is deemed to accrue or arise in India by virtue of section 9(1)(vi);
Royalty to include and always have included consideration in respect of any right, property or information whether or not.
- the possession or control of such right, property or information is with the payer;
- such right, property or information is used directly by the payer.
- the location of such right, property or information is in India.