Sale of Business Information Report by a non-resident can not be treated as ‘royalty’ taxable in India

Court: Mumbai bench of the Income tax Appellate Tribunal

Citation: M/s Dun & Bradstreet Information Services India Pvt. Ltd. Vs. ADIT [2010-TII-59- ITAT-MUM-INTL]

Brief :ITAT held that the consideration paid by the taxpayer to foreign affiliates for purchase of Business Information Report (BIR) was not ‘royalty’ within the meaning of explanation 2(iv) to section 9(1 )(vi) of the Income-tax Act, 1961 (the Act). Further, no withholding

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