https://www.taxtmi.com/caselaws?id=62863 Consideration paid for design and documentation supplied by a French contractor was treated as royalty because the material embodied information derived from industrial, commercial or scientific experience. On that footing, the definition of royalty in section 9(1)(vi) of the Income-tax Act and Article VII of the India-France treaty was wide enough to bring the payment to tax in India, and the absence of a permanent establishment did not prevent taxation of the royalty component. The contract was also severable, so the documentation payment could be examined separately from other services, and tax deduction at source was required. en-us Wed, 18 Jul 1990 00:00:00 +0530 Sat, 22 Jan 2011 12:44:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62863 Consideration paid for design and documentation supplied by a French contractor was treated as royalty because the material embodied information derived from industrial, commercial or scientific experience. On that footing, the definition of royalty in section 9(1)(vi) of the Income-tax Act and Article VII of the India-France treaty was wide enough to bring the payment to tax in India, and the absence of a permanent establishment did not prevent taxation of the royalty component. The contract was also severable, so the documentation payment could be examined separately from other services, and tax deduction at source was required. Case-Laws Income Tax Wed, 18 Jul 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62863