https://www.taxtmi.com/caselaws?id=800210 Royalty payable by non-resident customers is chargeable in India only where the licensed right, property or information is used in the payer's Indian business or to earn income from an identifiable Indian source. A multi-territorial licence that includes India, without customer-specific evidence of that nexus, does not satisfy the domestic source condition; indirect commercial use does not remove it. Treaty analysis distinguishes effective connection with the recipient's permanent establishment from royalty situs based on the payer's residence or permanent establishment. Where declarations show no Indian permanent establishment or fixed base and no contrary material exists, treaty situs conditions remain unmet. Subject to verification, the licensing receipts are not taxable in India. en-us Mon, 24 Aug 2026 00:00:00 +0530 Sat, 03 Oct 2026 09:32:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800210 Royalty payable by non-resident customers is chargeable in India only where the licensed right, property or information is used in the payer's Indian business or to earn income from an identifiable Indian source. A multi-territorial licence that includes India, without customer-specific evidence of that nexus, does not satisfy the domestic source condition; indirect commercial use does not remove it. Treaty analysis distinguishes effective connection with the recipient's permanent establishment from royalty situs based on the payer's residence or permanent establishment. Where declarations show no Indian permanent establishment or fixed base and no contrary material exists, treaty situs conditions remain unmet. Subject to verification, the licensing receipts are not taxable in India. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800210