Payment received for sale of copyright article does not amount to royalty under the India – USA tax treaty

Court : Mumbai bench of the Income Tax Appellate Tribunal

Citation : DDIT Vs. Alcatel USA International Marketing Inc [2010-TII-123-ITAT-MUM-INTL]

Brief :Recently, the Mumbai bench of the Income-tax Appellate Tribunal held that the payment received by the taxpayer company towards the sale of copyright article does not amount to royalty within the provisions of Article 12(3) of the India-USA tax treaty (tax treaty).

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