The assessee, an accredited domain name registrar in the United States, facilitated registration of domain names but neither owned nor possessed proprietary rights in the domain names. The Tribunal held that the assessee merely acted as a registrar and could not grant any right to use the domain names. Accordingly, the receipts from domain name registration services did not constitute royalty under section 9(1)(vi) of the Act or Article 12(3) of the India-USA DTAA.  The Tribunal held that web hosting, web designing and other non-domain services are independent of domain name registration services. Merely because such services may be purchased together or utilise the same server does not make them ancillary or subsidiary to domain name registration. The receipts were therefore not taxable as Fees for Technical Services under the India-USA DTAA.(The Tribunal held that the services rendered by the assessee did not “make available” any technical knowledge, skill, know-how or process enabling the customers to perform such functions independently. The services merely enabled customers to use the facilities provided by the assessee and involved no transfer of technical knowledge or enduring benefit. Accordingly, the receipts were not taxable as Fees for Included Services under Article 12(4)(b) of the India-USA DTAA AY. 2016-17 to 2019-20 & 2021-22).