Hireright Ltd. v. ACIT (2025) 213 ITD 138 (Delhi)(Trib.)

S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Screening and investigation services to its customers in India-Not royalty-Addition was deleted-India-UK. [Art. 5, 13]

On appeal, the Tribunal held that where the assessee, a UK-based company, provided background screening and investigation services to its customers in India, since said services did not qualify as royalty under provisions of Explanation 2 to section 9(1)(vi) and article 13 of the India-UK DTAA, no addition on account of royalty was warranted. (AY. 2022-23)

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