https://www.taxtmi.com/caselaws?id=415881 Receipts from granting access to a database were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-USA DTAA because the payer obtained only use of the product, not any right to exploit copyright. The assessee retained legal title and exclusive rights in the copyrighted material, and the distributor had no authority to reproduce, translate, or adapt the data. The arrangement was therefore characterised as use of a copyrighted article rather than transfer or use of copyright, and the addition was deleted. en-us Tue, 14 Dec 2021 00:00:00 +0530 Wed, 17 Sep 2025 17:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415881 Receipts from granting access to a database were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-USA DTAA because the payer obtained only use of the product, not any right to exploit copyright. The assessee retained legal title and exclusive rights in the copyrighted material, and the distributor had no authority to reproduce, translate, or adapt the data. The arrangement was therefore characterised as use of a copyrighted article rather than transfer or use of copyright, and the addition was deleted. Case-Laws Income Tax Tue, 14 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415881