https://www.taxtmi.com/caselaws?id=220518 Receipts for collated information and data supplied to an Indian affiliate were treated as business income under Article 7, because the payment did not involve exploitation of know-how or transfer of technical skill sufficient to constitute royalty or fees for included services under Article 12. The residuary Article 22 was held inapplicable because treaty taxation must first be tested under the specific charging provision that governs the income. Following earlier Mumbai Tribunal orders on similar facts, the receipt was therefore not royalty and was not taxable under Article 22. en-us Wed, 16 Jan 2013 00:00:00 +0530 Fri, 24 Apr 2015 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220518 Receipts for collated information and data supplied to an Indian affiliate were treated as business income under Article 7, because the payment did not involve exploitation of know-how or transfer of technical skill sufficient to constitute royalty or fees for included services under Article 12. The residuary Article 22 was held inapplicable because treaty taxation must first be tested under the specific charging provision that governs the income. Following earlier Mumbai Tribunal orders on similar facts, the receipt was therefore not royalty and was not taxable under Article 22. Case-Laws Income Tax Wed, 16 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220518