https://www.taxtmi.com/caselaws?id=781346 Receipts from Indian subscribers for access to online journals, online libraries and online databases were treated as consideration for copyrighted articles, not royalty, because no copyright or right to exploit copyright was transferred. The distinction applied was between use of copyright and mere use of copyrighted material. The receipts were also not fees for technical services or fees for included services under the India-USA tax treaty, as the arrangement did not involve technical or consultancy services satisfying the make-available requirement. The addition was therefore deleted and the amounts were held not taxable on those grounds. en-us Mon, 10 Nov 2025 00:00:00 +0530 Fri, 14 Nov 2025 09:42:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781346 Receipts from Indian subscribers for access to online journals, online libraries and online databases were treated as consideration for copyrighted articles, not royalty, because no copyright or right to exploit copyright was transferred. The distinction applied was between use of copyright and mere use of copyrighted material. The receipts were also not fees for technical services or fees for included services under the India-USA tax treaty, as the arrangement did not involve technical or consultancy services satisfying the make-available requirement. The addition was therefore deleted and the amounts were held not taxable on those grounds. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781346