https://www.taxtmi.com/caselaws?id=781345 Limited access to a copyrighted article or database, without transfer of copyright or any right to exploit the underlying intellectual property, is not royalty under section 9(1)(vi) of the Income-tax Act or the relevant DTAA. The Tribunal held that administration fees for IMEI allocation and subscription fees for database and research access were paid only for restricted use of copyrighted content, not for use of copyright or any intellectual property right, and followed its earlier coordinate bench view and treaty analysis. Both additions treating the receipts as royalty were deleted, in favour of the assessee. en-us Tue, 04 Nov 2025 00:00:00 +0530 Fri, 14 Nov 2025 09:42:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781345 Limited access to a copyrighted article or database, without transfer of copyright or any right to exploit the underlying intellectual property, is not royalty under section 9(1)(vi) of the Income-tax Act or the relevant DTAA. The Tribunal held that administration fees for IMEI allocation and subscription fees for database and research access were paid only for restricted use of copyrighted content, not for use of copyright or any intellectual property right, and followed its earlier coordinate bench view and treaty analysis. Both additions treating the receipts as royalty were deleted, in favour of the assessee. Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781345