Scope of section 80-O clarified: trademark payments treated as royalty and composite agreements approved with suitable disallowance. The Circular removes the requirement that agreements be entered on or after a Bill's introduction for approval under Section 80-O, treats payments for use of trade-marks as royalty within the section's scope, and permits approval of composite agreements subject to suitable disallowance for non-qualifying services so that the balance attributable to know how or technical services qualifying under the section may be exempted.
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Provisions expressly mentioned in the judgment/order text.
Scope of section 80-O clarified: trademark payments treated as royalty and composite agreements approved with suitable disallowance.
The Circular removes the requirement that agreements be entered on or after a Bill's introduction for approval under Section 80-O, treats payments for use of trade-marks as royalty within the section's scope, and permits approval of composite agreements subject to suitable disallowance for non-qualifying services so that the balance attributable to know how or technical services qualifying under the section may be exempted.
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