https://www.taxtmi.com/caselaws?id=6604 Consideration paid by Indian subscribers for access to and use of a Singapore-hosted cargo booking portal and its integrated server platform was treated as royalty under Article 12(3)(b) and section 9(1)(vi), because the portal and server were regarded as equipment used for commercial purposes. Training and helpdesk support provided in India were held ancillary to that use and also qualified as fees for technical services under Article 12 and section 9(1)(vii). The receipts were therefore not taxable as business profits under Article 7, and the alternative reliance on Article 8 failed. The amounts were taxable in India and subject to tax deduction at source. en-us Mon, 22 Jan 2007 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6604 Consideration paid by Indian subscribers for access to and use of a Singapore-hosted cargo booking portal and its integrated server platform was treated as royalty under Article 12(3)(b) and section 9(1)(vi), because the portal and server were regarded as equipment used for commercial purposes. Training and helpdesk support provided in India were held ancillary to that use and also qualified as fees for technical services under Article 12 and section 9(1)(vii). The receipts were therefore not taxable as business profits under Article 7, and the alternative reliance on Article 8 failed. The amounts were taxable in India and subject to tax deduction at source. Case-Laws Income Tax Mon, 22 Jan 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6604