Subscription Charges Not "Royalty" u/s 9(1)(vi) of Income Tax Act and India-USA DTAA Article 12(3.

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....Income accued in India - taxability of subscription charges received by the assessee as “Royalty” - the income earned by way of CAS fee are squarely applicable to the subscription revenue received from customers of PUBS division for sale of journal also, and accordingly PUBS fee also does not qualify as 'Royalty' in terms of section 9(1)(vi) of the Act as well as Article 12(3) of the India-USA DTAA.” - AT....