Income from Subscription-Based Access to Online Database Not Taxed as Royalty in India Under Article 12(3.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Royalty - Income taxable in India or not - access to online database of journals and books - it is very much clear, only limited right of access to the database was granted to customers on subscription basis. Therefore, in our view, the amount received will not fall within the ambit of royalty as defined under Article 12(3) of the tax treaty. - AT....