P.V. Reddi, Chairman. - This application is filed under section 245Q(1) of the Income-tax Act, 1961 (for short ‘the Act’). The applicant (referred to hereinafter as ‘FactSet’) is a company incorporated in USA and is non-resident for the purpose of Income-tax Act.

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 worldwide. 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 FactSet, though the information contained in the database is available in public domain. The applicant, however, through its database enables the customer to retrieve this publicly available information within a shorter span of time and in a focused manner. The database maintains historical information and all the databases of FactSet are maintained at its datacenters in USA. For a customer to access and view Fac