https://www.taxtmi.com/caselaws?id=437735 Subscription income for access to an online database was analysed under section 9(1)(vi) and Article 12(3) of the India-Switzerland DTAA, and the Tribunal applied its earlier rulings on identical IQVIA subscription receipts. As the treaty wording was materially identical and no distinguishing facts or legal change were shown, the principle of consistency was followed. The subscription fees were treated as not constituting royalty and were therefore not taxable as royalty. Grounds relating to recomputation of income were not pressed, and the interest issues were consequential. en-us Thu, 27 Apr 2023 00:00:00 +0530 Fri, 12 May 2023 09:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437735 Subscription income for access to an online database was analysed under section 9(1)(vi) and Article 12(3) of the India-Switzerland DTAA, and the Tribunal applied its earlier rulings on identical IQVIA subscription receipts. As the treaty wording was materially identical and no distinguishing facts or legal change were shown, the principle of consistency was followed. The subscription fees were treated as not constituting royalty and were therefore not taxable as royalty. Grounds relating to recomputation of income were not pressed, and the interest issues were consequential. Case-Laws Income Tax Thu, 27 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437735