Fiserv Inc., a company headquartered in Country F, operates an online platform that provides end-user computer software under an End-User License…

Fiserv Inc., a company headquartered in Country F, operates an online platform that provides end-user computer software under an End-User License Agreement (EULA). In the Financial Year 2024-25, Turmeric Ltd., an Indian company, entered into a contract for 6.7 crore with Fiserv Inc., which is approved by the Central Government. Under the EULA, Fiserv Inc. grants Turmeric Ltd. a limited, non-exclusive license to install, use, access, display, and run the click-wrap web-based computer software (CWCS) on a single local hard disk or another permanent storage medium of one computer. However, Turmeric Ltd. is restricted from making the CWCS available over a network where it could be used by multiple computers at the same time. Fiserv Inc. reserves all rights not explicitly granted to Turmeric Ltd. under the EULA. The CWCS is protected by copyright and other intellectual property laws and treaties. Fiserv Inc. owns the title, copyright and other intellectual property rights in the CWCS. The CWCS is licenced (only for use and not any other purpose), not sold. Fiserv Inc. does not have any offices outside Country F. Extract of Article 12 of India-Country F DTAA Royalties and Fees for Technical Services Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties or fees for technical services, the tax so charged shall not exceed 10 per cent.The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use : any copyright of a literary, artistic or scientific work, including cinematograph film or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, including gains derived from the alienation of any such right, property or information From the information given above, choose the most appropriate answer from MCQ 9 to MCQ 12 below: