IQVIA AG,SWITZERLAND vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNALTIONAL TAXATION) - 2(2)(2), MUMBAI

ITA 4549/MUM/2023Status: DisposedITAT Mumbai02 December 2025AY 2021-22Bench: MS. PADMAVATHY S (Accountant Member), SHRI RAJ KUMAR CHAUHAN (Judicial Member)18 pages
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What did the Tribunal hold?

The Tribunal held that the subscription income is not royalty as it does not involve the transfer of a right to use copyright or imparting of information concerning industrial, commercial, or scientific knowledge. The Tribunal followed its own earlier decisions in favor of the assessee.

What were the facts?

The assessee, a Swiss company, received subscription fees from Indian customers for online reports on the pharmaceutical sector. The Assessing Officer (AO) treated these fees as royalty income taxable in India.

What were the issues?

Whether subscription fees received by a foreign company for online reports constitute royalty income taxable in India under the Income Tax Act and the India-Switzerland DTAA.

Which sections of the Income-tax Act were involved?

Section 9(1)(vi),Section 144C(5)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “I”, MUMBAI

Before: MS. PADMAVATHY S & SHRI RAJ KUMAR CHAUHAN

For Appellant: Shri Madhur Agarwal &, Shri Fenil Bhatt, Ld ARs
For Respondent: Shri Krishna Kumar, Ld
Pronounced: 02.12.2025

Heard together (2 matters)

ITA NO. 3359/MUM/2023
ITA NO. 4549/MUM/2023

Read from the judgment's own cause title. This page is filed under one of them.

PER RAJ KUMAR CHAUHAN (J.M.):

1.

Both the appeals are filed by the appellant/assessee against the assessment order dated 27.07.2023 and 16.10.2026 passed by the AO in pursuant to the direction issued by Ld. DRP, Mumbai u/s 144C(5) of the Income Tax Act, 1961 [hereinafter refer

The order continues below.

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