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https://blog.scconline.com/post/2019/07/21/itat-india-germany-tax-treaty-subscription-fee-earned-by-elsevier-for-online-database-held-not-royalty-or-fee-for-technical-services-and-thus-not-taxable-in-india/
ITAT | India-Germany Tax Treaty | Subscription fee earned by Elsevier for online database held not royalty or fee for technical services, and thus not taxable in India