https://www.taxtmi.com/caselaws?id=436247 Subscription fee for access to an online database of journals and books was held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-USA DTAA. The database was compiled from public-domain material with limited value additions, and subscribers received only viewing access subject to strict restrictions on copying, reproduction, modification, reverse engineering and exploitation. Because no copyright right, equipment right or similar property right was transferred, the payment was treated as consideration for limited access to information rather than for use of, or right to use, royalty-bearing rights. The earlier contrary view was displaced by Engineering Analysis, and the receipt was not taxable in India absent a permanent establishment. en-us Tue, 28 Feb 2023 00:00:00 +0530 Wed, 01 Apr 2026 14:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436247 Subscription fee for access to an online database of journals and books was held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-USA DTAA. The database was compiled from public-domain material with limited value additions, and subscribers received only viewing access subject to strict restrictions on copying, reproduction, modification, reverse engineering and exploitation. Because no copyright right, equipment right or similar property right was transferred, the payment was treated as consideration for limited access to information rather than for use of, or right to use, royalty-bearing rights. The earlier contrary view was displaced by Engineering Analysis, and the receipt was not taxable in India absent a permanent establishment. Case-Laws Income Tax Tue, 28 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436247