Consideration for Grant of the use or consideration for right to use is Royalty

The applicant is in the business of gathering, collating and making available or imparting information concerning industrial and commercial knowledge, experience and skill and consequently the payment received from the subscriber would be royalty in terms of clause (iv) of Explanation 2 to Section 9(1)(vi) of the Act. If so, the subscription received is royalty liable to be taxed as such under the Act. Going by the DTAC between India and Singapore, it will qualify as royalty since it is the grant of the use for consideration or right to use for consideration, the process or information concer...