‘Subscription fees’ received by assessee has to be assessed as ‘business income’ as per the provisions of DTAA between India and Singapore

Whether the ld CIT(A) is justified in holding that the amount received by the appellant from the subscribers are in the nature of fees for technical services to the extent of subscription fees received for providing information/data on various products like financial/ forex/ commodity market and  ‘royalty’ for use of equipment such as shared printer, matrix etc., and accordingly, entire receipts are liable to tax @ 20% on gross basis u/s  44D r.w.s 115A. ‘Subscription fees’ received by the assessee has to be assessed as ‘business income’ as per the provisions of DTAA between Indi...