https://www.taxtmi.com/caselaws?id=210062 Royalty paid under technical collaboration agreements for know-how, brand use, supervision, training, quality assurance and product development was treated as deductible business expenditure where the taxpayer showed continuing commercial benefit and a rate consistent with comparable arrangements. Article 9 of the Double Taxation Avoidance Agreement was held not to authorise disallowance of the resident assessee's expenditure, and the payment was not found excessive or unreasonable on the facts. RBI approval was also held to be limited to foreign exchange regulation and did not prevent income-tax authorities from examining deductibility, genuineness or reasonableness under the Act, including scrutiny under Section 40A(2). en-us Wed, 11 May 2011 00:00:00 +0530 Mon, 12 Jun 2023 10:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210062 Royalty paid under technical collaboration agreements for know-how, brand use, supervision, training, quality assurance and product development was treated as deductible business expenditure where the taxpayer showed continuing commercial benefit and a rate consistent with comparable arrangements. Article 9 of the Double Taxation Avoidance Agreement was held not to authorise disallowance of the resident assessee's expenditure, and the payment was not found excessive or unreasonable on the facts. RBI approval was also held to be limited to foreign exchange regulation and did not prevent income-tax authorities from examining deductibility, genuineness or reasonableness under the Act, including scrutiny under Section 40A(2). Case-Laws Income Tax Wed, 11 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210062