https://www.taxtmi.com/caselaws?id=435322 Receipts from distance education and database access were treated as royalty under the Income-tax Act and the India-Malaysia DTAA, but the record was incomplete and the agreements and supporting documents had not been fully verified. Because additional material required examination, the Revenue sought remand, and the matter was restored to the Assessing Officer for fresh decision after proper factual verification and consideration of the earlier year's treatment under the applicable treaty principles. The substantive taxability issue was left open for reconsideration. en-us Tue, 30 Aug 2022 00:00:00 +0530 Thu, 16 Mar 2023 14:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435322 Receipts from distance education and database access were treated as royalty under the Income-tax Act and the India-Malaysia DTAA, but the record was incomplete and the agreements and supporting documents had not been fully verified. Because additional material required examination, the Revenue sought remand, and the matter was restored to the Assessing Officer for fresh decision after proper factual verification and consideration of the earlier year's treatment under the applicable treaty principles. The substantive taxability issue was left open for reconsideration. Case-Laws Income Tax Tue, 30 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435322