https://www.taxtmi.com/caselaws?id=11683 A payment for supplied market data is royalty only if the information carries specialised technical, industrial, commercial, scientific knowledge, experience, or skill under Explanation 2 to section 9(1)(vi) and the applicable treaty. The Court held that not every item of commercial information becomes royalty merely because it relates to business activity. However, the Tribunal had not been given the underlying data compilation, so its finding that the payment was not royalty lacked an adequate factual foundation. The Tribunal's order was set aside and the matter was remitted for fresh decision after production of the relevant material. en-us Mon, 05 May 2003 00:00:00 +0530 Fri, 05 Feb 2010 18:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11683 A payment for supplied market data is royalty only if the information carries specialised technical, industrial, commercial, scientific knowledge, experience, or skill under Explanation 2 to section 9(1)(vi) and the applicable treaty. The Court held that not every item of commercial information becomes royalty merely because it relates to business activity. However, the Tribunal had not been given the underlying data compilation, so its finding that the payment was not royalty lacked an adequate factual foundation. The Tribunal's order was set aside and the matter was remitted for fresh decision after production of the relevant material. Case-Laws Income Tax Mon, 05 May 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11683