https://www.taxtmi.com/caselaws?id=765215 Distance learning material supplied through independent training centres, sale of manuals and books, advertising space, and database access were treated as business receipts rather than royalty because no right to use copyright, brand, technical know-how, or other intellectual property was transferred. The authorised training centres and a third-party survey provider were not treated as dependent agent permanent establishments because the treaty conditions of devotion wholly or almost wholly to the enterprise and non-arm's-length dealing were not established. Receipts from the clearing house facility, joining and annual fees, and related data processing charges were treated as mutual receipts arising from a common fund for participating members, so they were not taxable in India on that basis. en-us Wed, 08 Jan 2025 00:00:00 +0530 Tue, 28 Jan 2025 08:24:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765215 Distance learning material supplied through independent training centres, sale of manuals and books, advertising space, and database access were treated as business receipts rather than royalty because no right to use copyright, brand, technical know-how, or other intellectual property was transferred. The authorised training centres and a third-party survey provider were not treated as dependent agent permanent establishments because the treaty conditions of devotion wholly or almost wholly to the enterprise and non-arm's-length dealing were not established. Receipts from the clearing house facility, joining and annual fees, and related data processing charges were treated as mutual receipts arising from a common fund for participating members, so they were not taxable in India on that basis. Case-Laws Income Tax Wed, 08 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765215