https://www.taxtmi.com/caselaws?id=285967 ITAT MUMBAI - AT held that subscription fees charged to Indian customers for software access and journal/database access do not constitute "royalty" under section 9(1)(vi) of the Act or Article 12(3) of the India-USA DTAA. The tribunal found customers acquire only the right to use copyrighted articles or software products, not the underlying copyright or the right to exploit it; consideration is therefore for a product/service, not royalty. Accordingly, such subscription revenues are not taxable as royalty in India. 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 ITAT MUMBAI - AT held that subscription fees charged to Indian customers for software access and journal/database access do not constitute "royalty" under section 9(1)(vi) of the Act or Article 12(3) of the India-USA DTAA. The tribunal found customers acquire only the right to use copyrighted articles or software products, not the underlying copyright or the right to exploit it; consideration is therefore for a product/service, not royalty. Accordingly, such subscription revenues are not taxable as royalty in India. Case-Laws Income Tax Tue, 30 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285967