Domain name registrar's income not taxable as royalty under DTAA.

The Income Tax Appellate Tribunal (ITAT) ruled that a domain name registrar's income from registration services is not taxable as royalty under Section 9(1)(vi) of the Income Tax Act and Article 12(3)(a) of the India-USA Double Taxation Avoidance Agreement (DTAA), as the registrar does not own or transfer rights to the domain names. The ITAT upheld the Delhi High Court's earlier decision and confirmed that the registrar, structured as a Limited Liability Partnership (LLP), qualifies for DTAA benefits. Additionally, income from non-domain services like web hosting and design is not taxable as fees for included services under Article 12(4)(b) of the DTAA. .....

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