https://www.taxtmi.com/caselaws?id=6589 Payments for electronically supplied Business Information Reports were treated as receipts from sale of copyrighted articles on a principal-to-principal basis, because no copyright or right to use copyright was transferred or licensed to the Indian purchaser. The receipts therefore constituted business profits under Article 7 of the India-UK treaty and not royalty. On the facts, no branch, office, fixed place, dependent agent, or other material showed a permanent establishment in India, so the Indian purchaser was not the non-resident's PE. As no PE existed, the business profits were not taxable in India under the treaty. en-us Wed, 26 Oct 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6589 Payments for electronically supplied Business Information Reports were treated as receipts from sale of copyrighted articles on a principal-to-principal basis, because no copyright or right to use copyright was transferred or licensed to the Indian purchaser. The receipts therefore constituted business profits under Article 7 of the India-UK treaty and not royalty. On the facts, no branch, office, fixed place, dependent agent, or other material showed a permanent establishment in India, so the Indian purchaser was not the non-resident's PE. As no PE existed, the business profits were not taxable in India under the treaty. Case-Laws Income Tax Wed, 26 Oct 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6589