https://www.taxtmi.com/caselaws?id=120989 A fixed-price outright purchase of designs and drawings from a German party was treated as acquisition of ownership in technical documents, not as payment for the use of, or a restricted right to use, those designs. On that basis, the amount did not constitute royalty under section 9 of the Income-tax Act, 1961 or the applicable DTAA, and tax was not required to be deducted under section 195(2). The Tribunal distinguished authority dealing with specialised technical information supplied for exclusive use under continuing restrictions, and held that the Finance Act, 2007 amendment to section 9 did not change the result because the payment did not fall within clauses (v), (vi) or (vii). en-us Wed, 05 Sep 2007 00:00:00 +0530 Wed, 25 Jul 2012 17:59:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=120989 A fixed-price outright purchase of designs and drawings from a German party was treated as acquisition of ownership in technical documents, not as payment for the use of, or a restricted right to use, those designs. On that basis, the amount did not constitute royalty under section 9 of the Income-tax Act, 1961 or the applicable DTAA, and tax was not required to be deducted under section 195(2). The Tribunal distinguished authority dealing with specialised technical information supplied for exclusive use under continuing restrictions, and held that the Finance Act, 2007 amendment to section 9 did not change the result because the payment did not fall within clauses (v), (vi) or (vii). Case-Laws Income Tax Wed, 05 Sep 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=120989