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    <description>Subscription receipts from Indian customers for access to online research products were treated as royalty under section 9(1)(vi) and Article 12 of the India-Ireland DTAA, rather than business income, because the Tribunal followed the consistent view already taken in the assessee&#039;s own earlier years. The access model operated through internet-based service agreements for fee-based use of research products, and the receipts were held to fall within the royalty scope under both domestic law and the treaty. The issue was therefore decided against the assessee and in favour of the Revenue.</description>
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