Approval of agreement under which assessee-company receives royalty, etc., from Government of foreign State or foreign enterprise, which is eligible for deduction under the section - Guidelines therefor
📋
Contents
Cases Cited
Referred In
Notifications
Circulars
Forms
Manuals
Acts
Rules & Regulations
Case Laws New
Ref Provisions New
Plus +
Source NTF
Summary
Similar
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Royalty deduction eligibility clarified to include trademark payments and permit approvals with allocations for composite agreements. Approval under section 80-O provides concessional tax treatment for royalty, commission, fees or similar payments from foreign governments or enterprises, subject to Board approval, bona fides, and assessment determination. Trademark payments are within the scope of royalty. Composite agreements may receive approval with suitable disallowance for non qualifying elements so that the qualifying portion may be exempted. The concession is conditional on receipt in convertible foreign exchange, restricted to Indian companies prospectively, and requires submission of a standard application with supporting agreement documentation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Royalty deduction eligibility clarified to include trademark payments and permit approvals with allocations for composite agreements.
Approval under section 80-O provides concessional tax treatment for royalty, commission, fees or similar payments from foreign governments or enterprises, subject to Board approval, bona fides, and assessment determination. Trademark payments are within the scope of royalty. Composite agreements may receive approval with suitable disallowance for non qualifying elements so that the qualifying portion may be exempted. The concession is conditional on receipt in convertible foreign exchange, restricted to Indian companies prospectively, and requires submission of a standard application with supporting agreement documentation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.