https://www.taxtmi.com/caselaws?id=237361 Subscription fees for access to a research website were treated as royalty because the arrangement granted only a restricted licence to use proprietary research products, with confidential logins and restrictive covenants against disclosure, copying, sublicensing and unauthorised access. The information was specialised and segmented, not public information, so the payment was for imparting technical, industrial, commercial or scientific knowledge and not for general access to published material. On that basis, the fee was held taxable as royalty under section 9(1)(vi) of the Income-tax Act, 1961 and article 13(3) of the India-UK tax treaty, and the addition was upheld. en-us Fri, 16 Nov 2012 00:00:00 +0530 Wed, 12 Nov 2025 16:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237361 Subscription fees for access to a research website were treated as royalty because the arrangement granted only a restricted licence to use proprietary research products, with confidential logins and restrictive covenants against disclosure, copying, sublicensing and unauthorised access. The information was specialised and segmented, not public information, so the payment was for imparting technical, industrial, commercial or scientific knowledge and not for general access to published material. On that basis, the fee was held taxable as royalty under section 9(1)(vi) of the Income-tax Act, 1961 and article 13(3) of the India-UK tax treaty, and the addition was upheld. Case-Laws Income Tax Fri, 16 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237361