Subscription Fee for Database Access Not Royalty as No Copyright Rights Were Transferred: ITAT Delhi

Bain & Company Vs D/ACIT (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi arose from a final assessment order dated 18 December 2024 passed by the Deputy/Assistant Commissioner of Income Tax (International Tax), Gurgaon under Section 143(3) read with Section 144C(13) of the Income-tax Act, 1961. The assessee is a foreign company resident of the United States engaged in consultancy services including strategy, performance improvement, organization enhancement, mergers and acquisitions, and private equity advisory. It also provides support services to its subsi...