Amount not being royalty cannot be brought to tax in India in absence of PE

Uptodate Inc Vs DCIT (ITAT Delhi)

ITAT Delhi held that amount received not being in the nature of royalty under Article 12(3) of the treaty cannot be brought to tax in India in absence of a Permanent Establishment (PE).

Please become a Premium member. If you are already a Premium member, login here to access the full content.