https://www.taxtmi.com/caselaws?id=365657 Subscription revenue from access to an integrated commercial system, software, equipment and connectivity was characterised as royalty under the Income-tax Act and the India-United Kingdom tax treaty because the payment was for use and right to use commercial equipment and an information-processing facility. Once so characterised, attribution under Article 13(6) was not available where the non-resident maintained that no permanent establishment existed in India. The note also records that section 234B interest is not chargeable on a non-resident payee where tax was deductible at source by the payer and no contrary binding authority displaced that principle. 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 access to an integrated commercial system, software, equipment and connectivity was characterised as royalty under the Income-tax Act and the India-United Kingdom tax treaty because the payment was for use and right to use commercial equipment and an information-processing facility. Once so characterised, attribution under Article 13(6) was not available where the non-resident maintained that no permanent establishment existed in India. The note also records that section 234B interest is not chargeable on a non-resident payee where tax was deductible at source by the payer and no contrary binding authority displaced that principle. Case-Laws Income Tax Fri, 03 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365657