Subscription Fees Not Taxable as Royalty or FTS u/s 9 of Indian Income Tax Act and India-Germany Tax Treaty.

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....Income accrued in India -Treating subscription fee received from the clients in India as Royalty/FTS within the meaning of section 9(1)(vi) and 9(1)(vii) r.w. Article -12 of India Germany Tax Treaty - Subscription fee received by the assessee is not in the nature of Royalty/FTS, the same is not taxable in India - AT....