https://www.taxtmi.com/caselaws?id=307825 The Tribunal ruled in favor of the assessee, a Swiss company, in the tax dispute regarding the taxability of subscription income as Royalty under the Income-tax Act and the India-Switzerland Double Taxation Avoidance Agreement. The Tribunal held that the subscription fees did not qualify as Royalty as they did not involve the transfer of copyright or imparting of specific knowledge. Consequently, the addition of Rs. 46,24,44,838 as Royalty was deleted. The Tribunal also addressed the issue of interest under Section 234B, which was rendered academic following the deletion of the main addition. The appeal was allowed on 11/05/2022. en-us Wed, 11 May 2022 00:00:00 +0530 Wed, 10 May 2023 10:55:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307825 The Tribunal ruled in favor of the assessee, a Swiss company, in the tax dispute regarding the taxability of subscription income as Royalty under the Income-tax Act and the India-Switzerland Double Taxation Avoidance Agreement. The Tribunal held that the subscription fees did not qualify as Royalty as they did not involve the transfer of copyright or imparting of specific knowledge. Consequently, the addition of Rs. 46,24,44,838 as Royalty was deleted. The Tribunal also addressed the issue of interest under Section 234B, which was rendered academic following the deletion of the main addition. The appeal was allowed on 11/05/2022. Case-Laws Income Tax Wed, 11 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307825