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        Case ID :
        Income Tax

        Income deemed to accrue or arise in India - treatment of...

        Tax Ruling: Subscription Fees Not Technical Services or Royalties for Publishing Business in India.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
                                Note: It is a system-generated summary and is for quick reference only.
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