https://www.taxtmi.com/caselaws?id=784156 The dominant issue was whether subscription fees received for providing online access to pharmaceutical market research reports constituted "royalty" under the India-Switzerland DTAA and were deemed to accrue or arise in India. The Tribunal held that the receipts were for access to information/reports on a subscription basis and did not involve transfer of copyright, use of any copyright rights, or licensing of intellectual property so as to fall within the treaty definition of royalty; following its earlier order in the taxpayer's own case, it rejected the revenue's characterization. Consequently, the addition made by the AO pursuant to DRP directions was deleted, the impugned order was set aside, and the appeal was allowed. 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 The dominant issue was whether subscription fees received for providing online access to pharmaceutical market research reports constituted "royalty" under the India-Switzerland DTAA and were deemed to accrue or arise in India. The Tribunal held that the receipts were for access to information/reports on a subscription basis and did not involve transfer of copyright, use of any copyright rights, or licensing of intellectual property so as to fall within the treaty definition of royalty; following its earlier order in the taxpayer's own case, it rejected the revenue's characterization. Consequently, the addition made by the AO pursuant to DRP directions was deleted, the impugned order was set aside, and the appeal was allowed. Case-Laws Income Tax Tue, 02 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784156