https://www.taxtmi.com/caselaws?id=400711 Non-exclusive, non-transferable access to standardised market research reports and databases was treated as payment for factual information products, not for use of copyright or other intellectual property rights, so the receipt was not royalty under the treaty and the domestic addition could not survive. The Tribunal also treated the lockdown period as an extraordinary circumstance for rule 34(5), construing "ordinarily" to allow exclusion of that period from the ninety-day pronouncement timeline. On that basis, the delayed pronouncement was regarded as legally sustainable in the exceptional pandemic setting. en-us Mon, 13 Jul 2020 00:00:00 +0530 Tue, 09 May 2023 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400711 Non-exclusive, non-transferable access to standardised market research reports and databases was treated as payment for factual information products, not for use of copyright or other intellectual property rights, so the receipt was not royalty under the treaty and the domestic addition could not survive. The Tribunal also treated the lockdown period as an extraordinary circumstance for rule 34(5), construing "ordinarily" to allow exclusion of that period from the ninety-day pronouncement timeline. On that basis, the delayed pronouncement was regarded as legally sustainable in the exceptional pandemic setting. Case-Laws Income Tax Mon, 13 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400711