Held that the subscription fees received by the assessee from its customers for providing access to databases and journals were not royalty as customers did not acquire copyright, and therefore, such fees were not liable to be taxed in India. (AY. 2021-22)
American Chemical Society v. Dy. CIT (IT) (2024) 111 ITR 38 (SN) (Mum)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Subscription fees received by the assessee from its customers for providing access to databases and journals were not royalty-DTAA-India-USA [Art. 12(3)