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    <title>2017 (11) TMI 1846 - ITAT MUMBAI</title>
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    <description>Subscription receipts for online research and database access were held taxable as royalty under the Income-tax Act and the India-Ireland tax treaty because the issue was covered by the Tribunal&#039;s earlier decision in the assessee&#039;s own case; the Revenue succeeded on this point. Interest under section 234B was held not leviable on the non-resident assessee because the Indian payer was obliged to deduct tax at source, so the advance tax liability did not arise in the same manner; the assessee succeeded on this point. The appeal therefore resulted in partial relief, with one issue decided for the Revenue and the other for the assessee.</description>
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      <description>Subscription receipts for online research and database access were held taxable as royalty under the Income-tax Act and the India-Ireland tax treaty because the issue was covered by the Tribunal&#039;s earlier decision in the assessee&#039;s own case; the Revenue succeeded on this point. Interest under section 234B was held not leviable on the non-resident assessee because the Indian payer was obliged to deduct tax at source, so the advance tax liability did not arise in the same manner; the assessee succeeded on this point. The appeal therefore resulted in partial relief, with one issue decided for the Revenue and the other for the assessee.</description>
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