https://www.taxtmi.com/caselaws?id=440121 Subscription receipts for access to databases, journals and online publications were treated as payment for a copyrighted article, not for the transfer or use of copyright itself, so they were not royalty under section 9(1)(vi) or Article 12(3) of the India-US treaty. Limited customer access for viewing and personal use did not amount to use of an exploitable intellectual property right or industrial, commercial or scientific equipment. The royalty addition was therefore deleted. The levy of interest under section 234A was not finally adjudicated and was remanded for fresh examination of whether the return was filed within the prescribed time under section 139(1). en-us Fri, 31 Mar 2023 00:00:00 +0530 Tue, 11 Jul 2023 08:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440121 Subscription receipts for access to databases, journals and online publications were treated as payment for a copyrighted article, not for the transfer or use of copyright itself, so they were not royalty under section 9(1)(vi) or Article 12(3) of the India-US treaty. Limited customer access for viewing and personal use did not amount to use of an exploitable intellectual property right or industrial, commercial or scientific equipment. The royalty addition was therefore deleted. The levy of interest under section 234A was not finally adjudicated and was remanded for fresh examination of whether the return was filed within the prescribed time under section 139(1). Case-Laws Income Tax Fri, 31 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440121