British Airline's ARS Payment in India Classified as Royalty; Section 9(1)(vi) Amendment and Finance Act, 2012 Unaffected by DTAA.

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....Income from royalty - bookings arising from India, the payment for Altea Reservation System (ARS) is made by the British Airways for the use of system for the purpose of business in India and for the purpose of earning income from India - Mere amendment to Section 9(1)(vi) cannot result in a change. - the Finance Act, 2012 will not affect Article 12 of the DTAAs - AT....