Whether payment by a resident to non-resident for imported software is payment of 'royalty' requiring to deduct tax u/s 195 or a transaction of purchase of goods?

S.9(1)(vi)(b) of the Income Tax Act, 1961 ("The Act") provides that income by way of royalty payable by a resident except where the royalty is payable in respect of any right, property or information used or services

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