Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2023 Year 2023 This

Income accued in India - taxability of subscription charges ...


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

July 11, 2023

Case Laws     Income Tax     AT

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

View Source

 


 

You may also like:

  1. Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

  2. Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

  3. The High Court examined reassessment proceedings involving income from aircraft leasing treated as royalty under the Income Tax Act and India-Ireland Double Taxation...

  4. Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty...

  5. The ITAT held that the appellant, being a domain name registrar, does not own the domain names it helps register and cannot confer the right to use or transfer such...

  6. The ITAT Delhi held that Bandwidth charges received by a non-resident corporate entity from India are not taxable as royalty income u/s 9(1)(vi) and Article 12(3) of...

  7. Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment...

  8. The assessee, a non-resident company incorporated in Singapore without a permanent establishment in India, received income from licensing of software to M/s. L&T Ltd....

  9. 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...

  10. The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

  11. Receipts from Indian customers for services provided outside India are not taxable u/s 9(1)(vi) of the Income Tax Act, 1961 read with Article 12 of the India-Singapore...

  12. Income accrued in India -Treating subscription fee received from the clients in India as Royalty/FTS within the meaning of section 9(1)(vi) and 9(1)(vii) r.w. Article...

  13. The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts...

  14. Income taxable in India - Royalty u/s. 9 and/or under Article- 12 of India - payments made in terms of Sponsorship Agreement - Singapore, DTAA - sponsorship of the ICC...

  15. Income from equipment rental sourced in India u/s 5(2) read with Section 9 of the Income Tax Act and Article 12 of India-Malaysia DTAA. DRP erred in ignoring exceptions...

 

Quick Updates:Latest Updates