Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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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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