https://www.taxtmi.com/caselaws?id=757376 Receipts from Indian customers for access to online journals, e-books and databases were treated as consideration for access to copyrighted articles, not as royalty, because the users obtained no right to exploit or use copyright in the underlying works. The arrangement also did not amount to fees for technical services, as it involved no human intervention and did not make available technical knowledge, skill, experience or know-how under the treaty standard. In the absence of a permanent establishment in India, the income was not taxable as business profits. The receipts were therefore held not taxable in India. en-us Wed, 21 Aug 2024 00:00:00 +0530 Thu, 22 Aug 2024 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757376 Receipts from Indian customers for access to online journals, e-books and databases were treated as consideration for access to copyrighted articles, not as royalty, because the users obtained no right to exploit or use copyright in the underlying works. The arrangement also did not amount to fees for technical services, as it involved no human intervention and did not make available technical knowledge, skill, experience or know-how under the treaty standard. In the absence of a permanent establishment in India, the income was not taxable as business profits. The receipts were therefore held not taxable in India. Case-Laws Income Tax Wed, 21 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757376