https://www.taxtmi.com/caselaws?id=432618 Under the India-UAE DTAA, domain name registration receipts were treated as facilitative services rather than consideration for any right to use intellectual property or equipment, so they did not constitute royalty. Web hosting receipts were also held not to be royalty because the customer received hosting facilities without control, possession, or an independent right to use the equipment or platform, and the treaty meaning of royalty was not expanded by domestic law amendments. Sponsorship income from a short India conference was treated as business income taxable in India only if the non-resident had a permanent establishment; in the absence of a fixed place of business, the receipts were not taxable as business profits. The disputed additions were therefore deleted. en-us Fri, 30 Dec 2022 00:00:00 +0530 Mon, 16 Jun 2025 12:48:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432618 Under the India-UAE DTAA, domain name registration receipts were treated as facilitative services rather than consideration for any right to use intellectual property or equipment, so they did not constitute royalty. Web hosting receipts were also held not to be royalty because the customer received hosting facilities without control, possession, or an independent right to use the equipment or platform, and the treaty meaning of royalty was not expanded by domestic law amendments. Sponsorship income from a short India conference was treated as business income taxable in India only if the non-resident had a permanent establishment; in the absence of a fixed place of business, the receipts were not taxable as business profits. The disputed additions were therefore deleted. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432618