https://www.taxtmi.com/caselaws?id=285967 Subscription receipts for access to scientific databases, journals, e-books and articles were analysed under section 9(1)(vi) and Article 12(3) of the India-USA DTAA. The arrangement gave subscribers only limited search, view, download, print or internal-use rights, with no transfer of copyright, no right to commercially exploit the material, and no access to undisclosed industrial or scientific experience. On that basis, the receipts were treated as consideration for copyrighted products, not for use of copyright or equipment. The CAS and PUBS receipts were therefore characterised as business receipts and not royalty taxable in India on that footing. en-us Tue, 30 Apr 2019 00:00:00 +0530 Wed, 17 Sep 2025 17:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285967 Subscription receipts for access to scientific databases, journals, e-books and articles were analysed under section 9(1)(vi) and Article 12(3) of the India-USA DTAA. The arrangement gave subscribers only limited search, view, download, print or internal-use rights, with no transfer of copyright, no right to commercially exploit the material, and no access to undisclosed industrial or scientific experience. On that basis, the receipts were treated as consideration for copyrighted products, not for use of copyright or equipment. The CAS and PUBS receipts were therefore characterised as business receipts and not royalty taxable in India on that footing. Case-Laws Income Tax Tue, 30 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285967