https://www.taxtmi.com/caselaws?id=420661 Subscription fees for CRM access and database use were not royalty where customers merely used a web-based platform to generate reports from their own data, while the assessee retained control over the servers, equipment, process and database infrastructure outside India. The arrangement did not confer any right to use the underlying equipment or process, nor did it make available any industrial, commercial or scientific experience, knowledge, skill, technique or methodology. The receipts were therefore outside royalty under section 9(1)(vi) and Article 12 of the India-Singapore DTAA, and the additions were deleted. en-us Fri, 25 Mar 2022 00:00:00 +0530 Tue, 18 Oct 2022 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420661 Subscription fees for CRM access and database use were not royalty where customers merely used a web-based platform to generate reports from their own data, while the assessee retained control over the servers, equipment, process and database infrastructure outside India. The arrangement did not confer any right to use the underlying equipment or process, nor did it make available any industrial, commercial or scientific experience, knowledge, skill, technique or methodology. The receipts were therefore outside royalty under section 9(1)(vi) and Article 12 of the India-Singapore DTAA, and the additions were deleted. Case-Laws Income Tax Fri, 25 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420661