https://www.taxtmi.com/caselaws?id=450324 HC upheld the Tribunal's finding that subscription fees for database access are business income not taxable as royalty or fees for included services; there was no PE in India. The court held mere access to a legal database does not transfer copyright or constitute making available technical knowledge, skill or consultancy under Section 9(1)(vii) or Article 12 of the DTAA. The assessee retained copyright and provided only use of a copy, so payments were not royalties or FTS. Decision affirmed in favour of the assessee and against the revenue. en-us Wed, 07 Feb 2024 00:00:00 +0530 Sat, 25 Oct 2025 13:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450324 HC upheld the Tribunal's finding that subscription fees for database access are business income not taxable as royalty or fees for included services; there was no PE in India. The court held mere access to a legal database does not transfer copyright or constitute making available technical knowledge, skill or consultancy under Section 9(1)(vii) or Article 12 of the DTAA. The assessee retained copyright and provided only use of a copy, so payments were not royalties or FTS. Decision affirmed in favour of the assessee and against the revenue. Case-Laws Income Tax Wed, 07 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450324