Taxation of royalties and technical service payments: share allotments to nonresidents for overseas delivery of machinery are taxable in India. Income embodied in shares allotted to non residents for delivery abroad of machinery and plant will attract Indian income tax because royalties and fees for technical services are deemed to accrue or arise in India under the 1976 amendments; the prior administrative concession in paragraph 11 of Public Circular No. 21 of 1969 is withdrawn and no longer insulates such share based payments from taxation as income received in India.
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Provisions expressly mentioned in the judgment/order text.
Taxation of royalties and technical service payments: share allotments to nonresidents for overseas delivery of machinery are taxable in India.
Income embodied in shares allotted to non residents for delivery abroad of machinery and plant will attract Indian income tax because royalties and fees for technical services are deemed to accrue or arise in India under the 1976 amendments; the prior administrative concession in paragraph 11 of Public Circular No. 21 of 1969 is withdrawn and no longer insulates such share based payments from taxation as income received in India.
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