https://www.taxtmi.com/caselaws?id=436213 Subscription receipts for access to an online legal and tax database were treated as business income rather than fees for technical services, because the arrangement involved only access to compiled electronic content and not the rendering of technical or consultancy services. The record showed no human intervention and no making available of technical knowledge, skill, or know-how to subscribers, so the receipts did not fall within section 9(1)(vii) of the Income-tax Act or Article 12 of the India-USA DTAA. In the absence of a permanent establishment in India, the receipts were therefore not taxable in India as business profits under Article 7 of the DTAA. en-us Wed, 05 Apr 2023 00:00:00 +0530 Fri, 07 Apr 2023 08:44:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436213 Subscription receipts for access to an online legal and tax database were treated as business income rather than fees for technical services, because the arrangement involved only access to compiled electronic content and not the rendering of technical or consultancy services. The record showed no human intervention and no making available of technical knowledge, skill, or know-how to subscribers, so the receipts did not fall within section 9(1)(vii) of the Income-tax Act or Article 12 of the India-USA DTAA. In the absence of a permanent establishment in India, the receipts were therefore not taxable in India as business profits under Article 7 of the DTAA. Case-Laws Income Tax Wed, 05 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436213