https://www.taxtmi.com/caselaws?id=334640 Subscription fees for Indian customers' online access to a research database were analysed as royalty rather than business income, because the access arrangement was treated consistently with earlier precedent involving the same transaction and treaty royalty principles. The Tribunal also considered reopening of assessment, noting that the reassessments were based on material arising from similar receipts in other years and that one year had only been processed under section 143(1), while another had not been originally assessed. Applying the reassessment principle recognised in Rajesh Jhaveri Stock Brokers, the reopening was supported. The appeals therefore failed on both the royalty issue and the reassessment challenge. en-us Wed, 21 Sep 2016 00:00:00 +0530 Thu, 17 Nov 2016 15:25:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334640 Subscription fees for Indian customers' online access to a research database were analysed as royalty rather than business income, because the access arrangement was treated consistently with earlier precedent involving the same transaction and treaty royalty principles. The Tribunal also considered reopening of assessment, noting that the reassessments were based on material arising from similar receipts in other years and that one year had only been processed under section 143(1), while another had not been originally assessed. Applying the reassessment principle recognised in Rajesh Jhaveri Stock Brokers, the reopening was supported. The appeals therefore failed on both the royalty issue and the reassessment challenge. Case-Laws Income Tax Wed, 21 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334640