Taxability of Income to American company by allowing use of its database located abroad to customers in India

RELEVANT PARAGRAPH 1.1   The following facts are stated in the application and in the written submissions filed: The applicant maintains a `database’ which is located outside India and which contains the financial and economic information including fundamental data of a large number of companies world-wise. The customers of the applicant are mostly financial intermediaries and investment banks which have the need for such data. The databases contain the published information collated, stored and displayed in an organized manner by Fact Set, though the information contained in the datab...