https://www.taxtmi.com/caselaws?id=294356 Receipts from Indian subscribers for non-exclusive, restricted web access to e-books, e-journals and e-articles were held not to be royalty under article 12(4) of the India-Netherlands DTAA because users received no copyright rights, proprietary interest or know-how, only limited self-use access to published content. The amounts were therefore treated as business income. On that basis, Indian subscribers were not required to deduct tax at source under section 195, since withholding would arise only if the income were chargeable to tax in India. en-us Mon, 03 Feb 2020 00:00:00 +0530 Wed, 07 Apr 2021 21:50:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294356 Receipts from Indian subscribers for non-exclusive, restricted web access to e-books, e-journals and e-articles were held not to be royalty under article 12(4) of the India-Netherlands DTAA because users received no copyright rights, proprietary interest or know-how, only limited self-use access to published content. The amounts were therefore treated as business income. On that basis, Indian subscribers were not required to deduct tax at source under section 195, since withholding would arise only if the income were chargeable to tax in India. Case-Laws Income Tax Mon, 03 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294356