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    <title>2022 (5) TMI 1547 - ITAT MUMBAI</title>
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    <description>Subscription receipts for non-exclusive, non-transferable access to standard online pharmaceutical database reports compiled from public-domain and collected data were examined as alleged royalty under the India-Switzerland DTAA. The Tribunal followed its own earlier ruling in the assessee&#039;s case, noting that the treaty royalty clause was materially the same, and held that such receipts did not amount to royalty under the DTAA. As the income was not taxable under the treaty, no adverse examination of the domestic provision was required, and the addition was deleted.</description>
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      <description>Subscription receipts for non-exclusive, non-transferable access to standard online pharmaceutical database reports compiled from public-domain and collected data were examined as alleged royalty under the India-Switzerland DTAA. The Tribunal followed its own earlier ruling in the assessee&#039;s case, noting that the treaty royalty clause was materially the same, and held that such receipts did not amount to royalty under the DTAA. As the income was not taxable under the treaty, no adverse examination of the domestic provision was required, and the addition was deleted.</description>
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