Receipt from domain name registration not fall in category of royalty & hence not taxable

PDR Solutions FZC Vs DCIT (ITAT Mumbai) ITAT Mumbai held that in absence of rights in the domain name, receipt from domain name registration doesn’t fall in the category of royalty as defined under Article 12(3) of India-UAE DTAA. Facts- The assessee is incorporated in United Arab Emirates and is a tax resident of UAE. The assessee is engaged in the business of web presence and sale of domain name of global customers. AO held that the assessee is giving the client right to use its domain name for a fixed period and for a fixed amount of time. Further, the assessee is not selling the domain n...