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The ITAT held that the appellant, being a domain name registrar, does not own the domain names it helps register and cannot confer the right to use or transfer such domain names. Therefore, the income earned from domain name registration services is not taxable as royalty u/s 9(1)(vi) of the Act and Article 12(3)(a) of the India-USA DTAA. The ITAT affirmed the Delhi HC's decision in the appellant's own case for earlier years. Regarding treaty benefits, the ITAT held that the appellant, being an LLP, is eligible for benefits under the DTAA, relying on precedents. The income from non-domain services like web hosting and web designing does not involve transfer of technical knowledge or know-how and hence cannot be taxed as fees for included services under Article 12(4)(b) of the DTAA.
The ITAT held that the appellant, being a domain name registrar, does not own the domain names it helps register and cannot confer the right to use or transfer such domain names. Therefore, the income earned from domain name registration services is not taxable as royalty u/s 9(1)(vi) of the Act and Article 12(3)(a) of the India-USA DTAA. The ITAT affirmed the Delhi HC's decision in the appellant's own case for earlier years. Regarding treaty benefits, the ITAT held that the appellant, being an LLP, is eligible for benefits under the DTAA, relying on precedents. The income from non-domain services like web hosting and web designing does not involve transfer of technical knowledge or know-how and hence cannot be taxed as fees for included services under Article 12(4)(b) of the DTAA.
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