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1. Income deemed to accrue or arise in India - Supply of software - ‘royalty’ - Shrink wrap software or customized software - Drawing parallels with that decision and the...

2. Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The...

3. DTAA between US & India - Royalty or sale of copyrighted articles / softwares - though the amount constitute royalty, but the same is not assessable in the hands of the...

4. Royalty income - distributing its products the Indian market - there is no transfer of legal title in the copyrighted article as the same rests with the assessee. All...

5. The case deals with the taxability of receipts from Indian customers for providing access to online databases/journals or sale of hard copy journals. The key points are:...

6. Royalty receipts or FTS - commission fee for payment “production and editorial charges”- the subscription amount cannot be treated as royalty, having regard to the fact...

7. Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of...

8. Taxability of an amount received from supply of drawings and designs - Accrual of income in India - Once the income from supply of plant and equipment is held to be not...

9. TDS u/s 195 - P.E. in India - The payments made by assessee to Gensler-USA were merely for project specific drawings & designs without transfer of technology or know-how...

10. Import of designs and drawings for manufacturing of ship - department was of the view that the drawings and designs cannot be classified under Chapter 49 inasmuch as...

11. TDS u/s 195 - Payment of royalty - disallowance u/s 40(a)(i) - What the appellant gets is only a copyrighted article to use the product for its internal business purpose...

12. Income accrued In India - receipts for design and drawing - Permanent Establishment [PE] in India - There is no dispute that the assessee has supplied only engineering...

13. TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

14. TDS deduction u/s 195 - Purchase of software - A copyrighted article is nothing but an article which incorporates the copyright of the owner, the assignee, the exclusive...

15. Income accrued in India - royalty or fees for technical services - subscription fees receipts for online data base - assessee only gets access to a copyrighted article...