Payment made for accreditation not covered by the definition of ‘royalty’ under Article 13(3) of India UK tax treaty

Advertisement ACIT Vs Anchor Health and Beauty Care Pvt Ltd (ITAT Mumbai)- Accreditation does not allow the accredited product to use, or have a right to use, a trademark, nor any information concerning industrial, commercial or scientific experience – or, for that purpose, use or right to use of anything falling in any other category of clause (a). An accreditation or approval by a reputed body may give certain comfort level to the end users of the product, and thus may constitute a USP (i.e. unique selling proposition) to that extent, but it may also be, therefore, used for the purpose...