https://www.taxtmi.com/caselaws?id=237361 ITAT Delhi (AT) held against the assessee, finding that subscription fees for access to a segmented, web-compiled scientific database constituted royalty. The licence was non-transferable, non-sublicensable and prohibited creation of derivative works, permitting limited downloading for permitted computers only. On these facts the information/knowledge accessed was supplied under a licence and thus fell within the domestic definition of royalty under section 9(1)(iv) and (vi) and article 13(3) of the DTAA with the U.K., making the fees taxable. 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 ITAT Delhi (AT) held against the assessee, finding that subscription fees for access to a segmented, web-compiled scientific database constituted royalty. The licence was non-transferable, non-sublicensable and prohibited creation of derivative works, permitting limited downloading for permitted computers only. On these facts the information/knowledge accessed was supplied under a licence and thus fell within the domestic definition of royalty under section 9(1)(iv) and (vi) and article 13(3) of the DTAA with the U.K., making the fees taxable. Case-Laws Income Tax Fri, 16 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237361