https://www.taxtmi.com/caselaws?id=769647 Receipts for background screening and investigation services were treated as consideration for supplying factual verification reports, not as payment for any right to use copyright, database rights, or another protected commercial or technical asset. Because the client received only reports for internal use and no right to reproduce, modify, exploit, or commercially use them, the payment did not fall within royalty under section 9(1)(vi) or Article 13 of the India-UK DTAA. The activity also did not involve making available technical knowledge, experience, skill, or know-how, or access to a database in the treaty sense. The addition was therefore not sustainable. en-us Wed, 23 Apr 2025 00:00:00 +0530 Tue, 29 Apr 2025 08:33:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769647 Receipts for background screening and investigation services were treated as consideration for supplying factual verification reports, not as payment for any right to use copyright, database rights, or another protected commercial or technical asset. Because the client received only reports for internal use and no right to reproduce, modify, exploit, or commercially use them, the payment did not fall within royalty under section 9(1)(vi) or Article 13 of the India-UK DTAA. The activity also did not involve making available technical knowledge, experience, skill, or know-how, or access to a database in the treaty sense. The addition was therefore not sustainable. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769647