https://www.taxtmi.com/caselaws?id=784156 Subscription fees for access to online pharmaceutical market research reports were analysed under the royalty and fees for technical services provisions, but the receipts arose from standard access to compiled reports sourced from public data and supplied on a non-exclusive, non-transferable basis. The Tribunal followed its earlier year rulings on materially identical facts and applied the principle of consistency, finding no reason to depart from that view. It held that the treaty, being more beneficial, prevailed and that the subscription receipts did not fall within the royalty limb on the facts presented, so they were not taxable in India as royalty. en-us Tue, 02 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 15:41:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784156 Subscription fees for access to online pharmaceutical market research reports were analysed under the royalty and fees for technical services provisions, but the receipts arose from standard access to compiled reports sourced from public data and supplied on a non-exclusive, non-transferable basis. The Tribunal followed its earlier year rulings on materially identical facts and applied the principle of consistency, finding no reason to depart from that view. It held that the treaty, being more beneficial, prevailed and that the subscription receipts did not fall within the royalty limb on the facts presented, so they were not taxable in India as royalty. Case-Laws Income Tax Tue, 02 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784156