Domain name registration income isn't royalty under Article 12(3) of India-UAE DTAA; no rights over domain name.

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....Royalty receipt - domain registration services - Domain names serve to identify such internet resources with a text base label that is easier to memorise than the numerical addresses used in the Internet Protocols. Domain names are also used as simple identification labels to indicate ownership or control of a resource. - since the assessee had no right in the domain name, the income received by the assessee from domain name registration does not fall in the category of royalty as defined under Article 12(3) of the India UAE DTAA. - AT....