https://www.taxtmi.com/caselaws?id=305375 The Tribunal held that the income, even if construed as Royalty, does not arise in India under Article 12(7) of the DTAA between India and Singapore because the payer is a resident of Singapore. It was emphasized that the state of source of royalties is where the payer resides. The Tribunal dismissed the Revenue's appeal based on a co-ordinate Bench decision and previous Tribunal rulings, determining that the Royalty did not arise in India as per the Treaty provisions. The judgment favored the assessee, with the issues of interpretation of the DTAA and nature of payment as Royalty decided in their favor. en-us Fri, 27 Dec 2013 00:00:00 +0530 Thu, 01 Dec 2022 15:47:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305375 The Tribunal held that the income, even if construed as Royalty, does not arise in India under Article 12(7) of the DTAA between India and Singapore because the payer is a resident of Singapore. It was emphasized that the state of source of royalties is where the payer resides. The Tribunal dismissed the Revenue's appeal based on a co-ordinate Bench decision and previous Tribunal rulings, determining that the Royalty did not arise in India as per the Treaty provisions. The judgment favored the assessee, with the issues of interpretation of the DTAA and nature of payment as Royalty decided in their favor. Case-Laws Income Tax Fri, 27 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305375