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Subscription fees received by US co. from Indian customers for access to its scientific database wasn't royalty

July 20, 2019[2019] 106 253 (Mumbai)

INTERNATIONAL TAXATION: Where assessee-US company collected publicly disclosed chemistry related scientific information into a database and research works of scientists worldwide into research journals, income earned by assessee by way of subscription fees from its Indian customers for providing access to such database and journals were not 'royalty' as customers did not acquire copyright; such fees were not liable to be taxed in India

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