https://www.taxtmi.com/caselaws?id=407754 Subscription fees for access to an online database were analysed under the Income-tax Act and the India-Germany Tax Treaty to determine whether they constituted royalty or fees for technical services. The arrangement gave only a non-exclusive, non-transferable right to access and use the database for the subscriber's own purposes, with no transfer of copyright or right to exploit any protected work. The activity involved collation and electronic access to publicly available material, without managerial, technical or consultancy services or human intervention. On that basis, and consistently with the assessee's earlier years, the receipts were treated as outside royalty and fees for technical services. en-us Mon, 03 May 2021 00:00:00 +0530 Thu, 20 May 2021 13:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407754 Subscription fees for access to an online database were analysed under the Income-tax Act and the India-Germany Tax Treaty to determine whether they constituted royalty or fees for technical services. The arrangement gave only a non-exclusive, non-transferable right to access and use the database for the subscriber's own purposes, with no transfer of copyright or right to exploit any protected work. The activity involved collation and electronic access to publicly available material, without managerial, technical or consultancy services or human intervention. On that basis, and consistently with the assessee's earlier years, the receipts were treated as outside royalty and fees for technical services. Case-Laws Income Tax Mon, 03 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407754