Following the asseesee’s own case for the Assessment year 2012-13 in DCIT v Reuters Transaction Services Ltd [2018] 96 taxmann.com 354 the Tribunal held that the amount received by the assessee from the customers in India is in the nature of royalty as per Article-13(3) of the India-UK Tax Treaty as well as the provisions of the Act. AY. 2014 -15 )
Reuters Transaction Services Ltd v. Dy . CIT ( 2020) 187 DTR 268/ 204 TTJ 624 ( Mum) ( Trib)
S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Subscription revenue received by the assessee to be in the nature of royalty and bringing it to tax in India.-DTAA -India -UK [ S.90 , 115A, Art , 13 (6) ]