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    <title>2023 (2) TMI 496 - ITAT DELHI</title>
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    <description>Domain name registration receipts were treated as royalty under section 9(1)(vi) because domain names were viewed as having characteristics analogous to a trademark and the activity involved use of an intangible property. Prior coordinate bench rulings in the same taxpayer&#039;s case were followed, and later contrary reliance did not alter the result. Web hosting receipts were treated as fee for technical services under section 9(1)(vii) and Article 12(4)(a) because they were ancillary to the domain name activity. The tax treatment adopted by the revenue was therefore sustained.</description>
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      <description>Domain name registration receipts were treated as royalty under section 9(1)(vi) because domain names were viewed as having characteristics analogous to a trademark and the activity involved use of an intangible property. Prior coordinate bench rulings in the same taxpayer&#039;s case were followed, and later contrary reliance did not alter the result. Web hosting receipts were treated as fee for technical services under section 9(1)(vii) and Article 12(4)(a) because they were ancillary to the domain name activity. The tax treatment adopted by the revenue was therefore sustained.</description>
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