https://www.taxtmi.com/caselaws?id=463835 Receipts from distribution rights and direct sales were analysed under the treaty royalty definition and were held not to be consideration for the use or right to use copyright; accordingly, they did not fall within royalty under the Income-tax Act or the India-UK DTAA. The same fact pattern as earlier years was followed, and no distinguishing material was shown. The Indian distributor was also not treated as an agency permanent establishment because the record did not establish the treaty conditions for a PE. The royalty additions were deleted, and the related PE finding was rejected. en-us Fri, 26 May 2023 00:00:00 +0530 Wed, 17 Sep 2025 19:22:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463835 Receipts from distribution rights and direct sales were analysed under the treaty royalty definition and were held not to be consideration for the use or right to use copyright; accordingly, they did not fall within royalty under the Income-tax Act or the India-UK DTAA. The same fact pattern as earlier years was followed, and no distinguishing material was shown. The Indian distributor was also not treated as an agency permanent establishment because the record did not establish the treaty conditions for a PE. The royalty additions were deleted, and the related PE finding was rejected. Case-Laws Income Tax Fri, 26 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463835