Godaddy.com LLC v. ACIT ( 2018) 193 TTJ 137/170 ITD 217 /165 DTR 57(Delhi)(Trib) , www.itatonline.org

S. 9(1)(vi):Income deemed to accrue or arise in India – Royalty – Domain name is an intangible asset which is similar to trademark. Consequently, income from services rendered in connection with such domain name registration is assessable as “royalty”-DTAA- India -USA [ S. 115A, Art .12 ]

Dismissing the appeal of the assesse the Tribunal held that ;Domain name is an intangible asset which is similar to trademark. Consequently, income from services rendered in connection with such domain name registration is assessable as “royalty”, therefore, the charges received by the assessee for services rendered in respect of domain name is royalty within the meaning of Clause (vi) read with Clause (iii) of Explanation 2 to Section 9(1) of Income-tax Act.( ITA No. 1878/Del/2017, dt. 03.04.2018)(AY.2013-14)