Accrual of income in India - Addition on account of royalty -...

Accrual of income in India - Addition on account of royalty - receipt from Indian customer for subscription to database, sale of e-journals and membership fees - India-US tax treaty - The tribunal sided with the appellant, referencing its own precedents which established that the subscription fees received for access to databases and journals did not constitute royalty. It was clarified that customers did not acquire any copyright but merely access to the copyrighted material, which does not qualify as royalty under the DTAA or the Income-tax Act.