Sale of Dangerous Goods Regulations manuals doesn’t tantamount to royalty

International Air Transport Association (Canada) Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that sale of Dangerous Goods Regulations manuals could not be characterised as ‘royalty’ within the meaning of Article 12(3) of the India-Canada tax treaty. Accordingly, addition towards sale of manuals is deleted.

Facts- The assessee has developed annual physical publications/manuals for e.g. ‘Dangerous Goods Regulations’ (‘DGR’) publications/manuals that provide information inter-alia pertaining to handling of shipment of dangerous goods. The

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