Subscription income received by a foreign entity from Indian clients is not Royalty in accordance with the India-Ireland tax treaty

Court: Mumbai bench of the Income-tax Appellate Tribunal

Citation: Gartner Ireland Ltd Vs. DDIT (ITA No. 1452/Mum/08) (Mum)

Brief :Mumbai bench of the Income-tax Appellate Tribunal held that subscription income received by a foreign entity from Indian clients is not in the nature of Royalty in accordance with the India-Ireland tax treaty (tax treaty).  Further, the Tribunal relying on various Supreme Court decisions observed that the order

Please become a Premium member. If you are already a Premium member, login here to access the full content.