https://www.taxtmi.com/caselaws?id=365657 Subscription revenue from Indian users may be characterised as royalty under the Income-tax Act and the India-United Kingdom tax treaty where contractual arrangements grant access to an integrated commercial system, software, equipment, connectivity and related information-processing facilities. Article 13(6) cannot be used for attribution to a permanent establishment where the taxpayer disputes having a permanent establishment in India. Interest under section 234B is not chargeable to a non-resident payee where the payer was required to deduct tax at source; the payer's failure to deduct does not create interest liability for the payee. en-us Fri, 03 Aug 2018 00:00:00 +0530 Tue, 21 Aug 2018 07:59:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365657 Subscription revenue from Indian users may be characterised as royalty under the Income-tax Act and the India-United Kingdom tax treaty where contractual arrangements grant access to an integrated commercial system, software, equipment, connectivity and related information-processing facilities. Article 13(6) cannot be used for attribution to a permanent establishment where the taxpayer disputes having a permanent establishment in India. Interest under section 234B is not chargeable to a non-resident payee where the payer was required to deduct tax at source; the payer's failure to deduct does not create interest liability for the payee. Case-Laws Income Tax Fri, 03 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365657