https://www.taxtmi.com/caselaws?id=449299 Administrative fee for access to an IMEI/TAC database is analysed as not constituting royalty under section 9(1)(vi) of the Income-tax Act, 1961 or Article 12(3) of the India-USA DTAA. The arrangement was treated as a revenue-sharing model involving maintenance and allocation of unique numbers, without transfer of any right to use intellectual property, imparting of technical, industrial, commercial or scientific experience, or use of industrial, commercial or scientific equipment. The text also notes that TDS credit depends on factual verification by the Assessing Officer before grant in accordance with law. en-us Fri, 08 Dec 2023 00:00:00 +0530 Fri, 09 Feb 2024 07:21:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449299 Administrative fee for access to an IMEI/TAC database is analysed as not constituting royalty under section 9(1)(vi) of the Income-tax Act, 1961 or Article 12(3) of the India-USA DTAA. The arrangement was treated as a revenue-sharing model involving maintenance and allocation of unique numbers, without transfer of any right to use intellectual property, imparting of technical, industrial, commercial or scientific experience, or use of industrial, commercial or scientific equipment. The text also notes that TDS credit depends on factual verification by the Assessing Officer before grant in accordance with law. Case-Laws Income Tax Fri, 08 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449299