https://www.taxtmi.com/caselaws?id=390511 Subscription revenue from Indian customers for access to a licensed platform, software, equipment, information and matching facilities was analysed as royalty under the Act and the India-United Kingdom Tax Treaty, because the payments were for use and right to use commercial equipment, software and information rather than a passive business receipt. The alternative plea that only royalty attributable to a permanent establishment in India could be taxed under Article 13(6) was rejected, as earlier coordinate bench rulings had already held that the attribution provision did not apply once the receipt was characterised as royalty. The commentary notes that identical facts were treated consistently with prior decisions. en-us Mon, 30 Dec 2019 00:00:00 +0530 Fri, 03 Jan 2020 13:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390511 Subscription revenue from Indian customers for access to a licensed platform, software, equipment, information and matching facilities was analysed as royalty under the Act and the India-United Kingdom Tax Treaty, because the payments were for use and right to use commercial equipment, software and information rather than a passive business receipt. The alternative plea that only royalty attributable to a permanent establishment in India could be taxed under Article 13(6) was rejected, as earlier coordinate bench rulings had already held that the attribution provision did not apply once the receipt was characterised as royalty. The commentary notes that identical facts were treated consistently with prior decisions. Case-Laws Income Tax Mon, 30 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390511