https://www.taxtmi.com/caselaws?id=773023 Receipts from domain name registration and web hosting services were analysed under section 9(1)(vi) of the Income-tax Act, 1961 and Article 12 of the India-UAE DTAA. The tribunal applied the narrower treaty definition of royalty and held that domestic enlarging explanations could not override the treaty. Domain registration receipts were treated as outside royalty because that service had already been settled by precedent. Web hosting receipts were also outside royalty because the arrangement did not confer possession, control, or a right to use equipment or the underlying platform. The additions were deleted on the basis that neither stream was taxable as royalty under the applicable DTAA. en-us Fri, 13 Jun 2025 00:00:00 +0530 Tue, 17 Jun 2025 07:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773023 Receipts from domain name registration and web hosting services were analysed under section 9(1)(vi) of the Income-tax Act, 1961 and Article 12 of the India-UAE DTAA. The tribunal applied the narrower treaty definition of royalty and held that domestic enlarging explanations could not override the treaty. Domain registration receipts were treated as outside royalty because that service had already been settled by precedent. Web hosting receipts were also outside royalty because the arrangement did not confer possession, control, or a right to use equipment or the underlying platform. The additions were deleted on the basis that neither stream was taxable as royalty under the applicable DTAA. Case-Laws Income Tax Fri, 13 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773023