https://www.taxtmi.com/caselaws?id=778540 Amounts received under a principal-to-principal distribution arrangement for access to a database and distribution rights were not royalty, because there was no transfer of copyright or right to use copyright under section 9(1)(vi) and Article 13(2) of the India-UK DTAA. No dependent agent permanent establishment was established, as the Indian distributor was not shown to habitually conclude contracts, hold stock for delivery, or secure orders wholly or almost wholly for the assessee; the profit attribution based on that alleged PE therefore failed. The Tribunal deleted the substantive additions, while directing verification of the limited TDS credit issue. en-us Mon, 15 Sep 2025 00:00:00 +0530 Thu, 18 Sep 2025 08:30:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778540 Amounts received under a principal-to-principal distribution arrangement for access to a database and distribution rights were not royalty, because there was no transfer of copyright or right to use copyright under section 9(1)(vi) and Article 13(2) of the India-UK DTAA. No dependent agent permanent establishment was established, as the Indian distributor was not shown to habitually conclude contracts, hold stock for delivery, or secure orders wholly or almost wholly for the assessee; the profit attribution based on that alleged PE therefore failed. The Tribunal deleted the substantive additions, while directing verification of the limited TDS credit issue. Case-Laws Income Tax Mon, 15 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778540