As per your advise to refered a case study, it seems to belonging a re-imbursement of expneses under service tax rules, but in our case it is pure purchase from us co.
A us co. manufactured a software which is required by our needs.
As per amendment in Budget 2012 any software purchase shall be deemed as royalty under sec 9(1)(vi) .
Now the safest option is to deduct TDS @ 25.75% (rate changed as per Budget 13), otherwise check whether any option as per DTAA. But DTAA option has to also go through PAN and TRC requirements.
CAclubindia
