https://www.taxtmi.com/caselaws?id=69867 The Tribunal applied substance over form to hold that amounts described as technical fees under a licence agreement were in reality royalty, because the arrangement involved supply of technical data, designs, specifications and related services for manufacture, with consideration linked to net invoiced value; the receipts were therefore to be reduced in computing chargeable profits under the Companies (Profits) Surtax Act, 1964. It also held that surtax payments made before filing the advance tax statement could still be treated as advance tax, and the absence of a formal statement did not make them ad hoc payments. en-us Fri, 08 Feb 1991 00:00:00 +0530 Tue, 12 Apr 2011 14:58:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69867 The Tribunal applied substance over form to hold that amounts described as technical fees under a licence agreement were in reality royalty, because the arrangement involved supply of technical data, designs, specifications and related services for manufacture, with consideration linked to net invoiced value; the receipts were therefore to be reduced in computing chargeable profits under the Companies (Profits) Surtax Act, 1964. It also held that surtax payments made before filing the advance tax statement could still be treated as advance tax, and the absence of a formal statement did not make them ad hoc payments. Case-Laws Income Tax Fri, 08 Feb 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69867