https://www.taxtmi.com/caselaws?id=70085 A lump sum received under a collaboration agreement for transfer of technical know-how and supporting documentation delivered abroad was not characterised as royalty because the know-how was supplied for plant set-up and there was no immediate use of it in India during the relevant year. The receipt was instead taxable as fees for technical services under the governing treaty and domestic law, as the arrangement concerned technical assistance and documentation linked to establishing the manufacturing unit rather than a royalty-bearing exploitation of know-how. On those facts, the tax treatment was determined in favour of the assessee and against the Revenue. en-us Fri, 02 Feb 2001 00:00:00 +0530 Thu, 14 Apr 2011 11:54:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70085 A lump sum received under a collaboration agreement for transfer of technical know-how and supporting documentation delivered abroad was not characterised as royalty because the know-how was supplied for plant set-up and there was no immediate use of it in India during the relevant year. The receipt was instead taxable as fees for technical services under the governing treaty and domestic law, as the arrangement concerned technical assistance and documentation linked to establishing the manufacturing unit rather than a royalty-bearing exploitation of know-how. On those facts, the tax treatment was determined in favour of the assessee and against the Revenue. Case-Laws Income Tax Fri, 02 Feb 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70085