https://www.taxtmi.com/caselaws?id=771991 Distance learning receipts were not taxable in India as business profits because the authorised training centres were independent third parties and the Revenue failed to establish the conditions for a dependent agent PE or non-arm's-length dealings; the related addition was deleted. Receipts from physical publications, advertising space and database access were not royalty because they involved sale of copyrighted articles or access to information, not a licence to exploit copyright or know-how; those additions were deleted. ICH facility receipts, joining and annual fees, and data processing charges were only partly resolved, with some items requiring verification or attribution review. Credit note claims and interest under sections 234A and 234B were directed to be verified or recomputed. en-us Tue, 29 Apr 2025 00:00:00 +0530 Sat, 31 May 2025 12:01:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771991 Distance learning receipts were not taxable in India as business profits because the authorised training centres were independent third parties and the Revenue failed to establish the conditions for a dependent agent PE or non-arm's-length dealings; the related addition was deleted. Receipts from physical publications, advertising space and database access were not royalty because they involved sale of copyrighted articles or access to information, not a licence to exploit copyright or know-how; those additions were deleted. ICH facility receipts, joining and annual fees, and data processing charges were only partly resolved, with some items requiring verification or attribution review. Credit note claims and interest under sections 234A and 234B were directed to be verified or recomputed. Case-Laws Income Tax Tue, 29 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771991