https://www.taxtmi.com/caselaws?id=432232 Remittance to the University of Cambridge for examination fees, books purchased and teacher training fees was analysed under section 9(1)(vi), section 9(2) and section 195 of the Income-tax Act, 1961, together with Article 13 of the India-UK DTAA. The payment was treated as falling within the same legal question previously decided in relation to Cambridge assessment receipts, where such receipts were held not to be royalty. Applying the principle that royalty arises only from use of, or the right to use, copyright or similar protected rights, the remittance did not fall within the royalty clause. As the treaty position was more beneficial, domestic royalty provisions were held inapplicable and no TDS was deductible. en-us Tue, 06 Dec 2022 00:00:00 +0530 Fri, 30 Dec 2022 12:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432232 Remittance to the University of Cambridge for examination fees, books purchased and teacher training fees was analysed under section 9(1)(vi), section 9(2) and section 195 of the Income-tax Act, 1961, together with Article 13 of the India-UK DTAA. The payment was treated as falling within the same legal question previously decided in relation to Cambridge assessment receipts, where such receipts were held not to be royalty. Applying the principle that royalty arises only from use of, or the right to use, copyright or similar protected rights, the remittance did not fall within the royalty clause. As the treaty position was more beneficial, domestic royalty provisions were held inapplicable and no TDS was deductible. Case-Laws Income Tax Tue, 06 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432232