https://www.taxtmi.com/caselaws?id=771609 Subscription receipts for cloud services were held not to constitute royalty under Article 12(3) of the India-Ireland Double Taxation Avoidance Agreement or section 9(1)(vi) of the Income-tax Act, 1961. The court relied on its earlier decisions in the assessee's own case and on its prior view in the same recurring controversy, finding no material change in either the facts or the legal position. On that basis, the receipts were treated as non-taxable royalty income, and the appeal was rejected. en-us Wed, 14 May 2025 00:00:00 +0530 Wed, 28 May 2025 08:26:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771609 Subscription receipts for cloud services were held not to constitute royalty under Article 12(3) of the India-Ireland Double Taxation Avoidance Agreement or section 9(1)(vi) of the Income-tax Act, 1961. The court relied on its earlier decisions in the assessee's own case and on its prior view in the same recurring controversy, finding no material change in either the facts or the legal position. On that basis, the receipts were treated as non-taxable royalty income, and the appeal was rejected. Case-Laws Income Tax Wed, 14 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771609