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The ITAT examined royalty receipts from online chemistry databases and journal subscriptions, determining that the subscription revenues from CAS and PUBS divisions do not constitute taxable royalty under Section 9(1)(vi) and Article 12(3) of the India-USA DTAA. Relying on the assessee's previous case for the assessment year 2014-15, the tribunal upheld the assessee's plea and directed the deletion of the tax addition. The appellate tribunal ultimately allowed the assessee's appeal, ruling that the subscription income was not taxable as royalty in the assessee's hands.
The ITAT examined royalty receipts from online chemistry databases and journal subscriptions, determining that the subscription revenues from CAS and PUBS divisions do not constitute taxable royalty under Section 9(1)(vi) and Article 12(3) of the India-USA DTAA. Relying on the assessee's previous case for the assessment year 2014-15, the tribunal upheld the assessee's plea and directed the deletion of the tax addition. The appellate tribunal ultimately allowed the assessee's appeal, ruling that the subscription income was not taxable as royalty in the assessee's hands.
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