https://www.taxtmi.com/caselaws?id=120741 Consideration for engineering drawings, designs and documentation supplied under a know-how and engineering agreement was treated as part of an offshore composite supply, because the documents were handed over outside India with title, ownership and risk passing abroad and no secret formula, patent, or mere right to use technical know-how was transferred. The payment was therefore not royalty under section 9(1)(vi) or Article 12 of the India-Germany tax treaty, and was not taxable in India on that basis. Reassessment was upheld because the original return had only been processed under section 143(1), so no opinion had been formed on the merits and reopening under section 147 was permissible. en-us Wed, 19 Dec 2007 00:00:00 +0530 Tue, 24 Jul 2012 10:02:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=120741 Consideration for engineering drawings, designs and documentation supplied under a know-how and engineering agreement was treated as part of an offshore composite supply, because the documents were handed over outside India with title, ownership and risk passing abroad and no secret formula, patent, or mere right to use technical know-how was transferred. The payment was therefore not royalty under section 9(1)(vi) or Article 12 of the India-Germany tax treaty, and was not taxable in India on that basis. Reassessment was upheld because the original return had only been processed under section 143(1), so no opinion had been formed on the merits and reopening under section 147 was permissible. Case-Laws Income Tax Wed, 19 Dec 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=120741