https://www.taxtmi.com/caselaws?id=450324 Subscription fees for access to an online legal database were held not to be royalty, because the arrangement granted only use of the facility and did not transfer copyright or a right to use copyright. The receipts were also not fees for technical services, as no managerial, technical or consultancy service was rendered and the make available condition was not met, since no technical knowledge, skill, know-how or process was imparted for independent future use. In the absence of a permanent establishment in India, the income was treated as business profit and not taxable in India. 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 Subscription fees for access to an online legal database were held not to be royalty, because the arrangement granted only use of the facility and did not transfer copyright or a right to use copyright. The receipts were also not fees for technical services, as no managerial, technical or consultancy service was rendered and the make available condition was not met, since no technical knowledge, skill, know-how or process was imparted for independent future use. In the absence of a permanent establishment in India, the income was treated as business profit and not taxable in India. Case-Laws Income Tax Wed, 07 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450324