Domain registration & web hosting not taxable as royalty under India-UAE DTAA

PDR Solutions FZC Vs ACIT (ITAT Delhi)

The Income Tax Appellate Tribunal (ITAT), Delhi Bench, has ruled in favor of PDR Solutions FZC, an assessee, by deleting additions made by the Assessing Officer (AO) that sought to tax receipts from ‘domain name registration services’ and ‘web hosting services’ as royalty income. The decision, pronounced in open court on June 13, 2025, clarifies the taxability of such digital services, particularly under the Double Taxation Avoidance Agreement (DTAA) between India and the UAE.

The case originated from an appeal f

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