https://www.taxtmi.com/caselaws?id=762530 Mere access to an online database containing books, journals, articles and analytical tools, without transfer of copyright or rendering of managerial, technical or consultancy services, did not amount to fees for technical services or royalty. The access arrangement did not make available technical knowledge, experience, skill, know-how or processes, so the subscription receipts could not be taxed in India on that basis under the Act or the India-UK DTAA. In the absence of a permanent establishment in India, the receipts were treated as business profits under the treaty and not as taxable technical service or royalty income. en-us Fri, 29 Nov 2024 00:00:00 +0530 Wed, 01 Apr 2026 14:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762530 Mere access to an online database containing books, journals, articles and analytical tools, without transfer of copyright or rendering of managerial, technical or consultancy services, did not amount to fees for technical services or royalty. The access arrangement did not make available technical knowledge, experience, skill, know-how or processes, so the subscription receipts could not be taxed in India on that basis under the Act or the India-UK DTAA. In the absence of a permanent establishment in India, the receipts were treated as business profits under the treaty and not as taxable technical service or royalty income. Case-Laws Income Tax Fri, 29 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762530