https://www.taxtmi.com/caselaws?id=221198 An agreement for development of a printer solution was found to go beyond a mere supply of machinery because it granted exclusive ownership of foreground intellectual property, rights to pursue patent and design applications, and restrictions on the supplier's later use of the technology. On that basis, the associated payment was characterised as involving transfer of technology and technical know-how, bringing it within royalty and fees for technical services rather than simple goods consideration. The separate question of whether a lower withholding tax rate applied under section 115A(1)(b)(BB) was not examined below and was restored for limited reconsideration. en-us Wed, 16 Jan 2013 00:00:00 +0530 Wed, 27 Feb 2013 06:24:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=221198 An agreement for development of a printer solution was found to go beyond a mere supply of machinery because it granted exclusive ownership of foreground intellectual property, rights to pursue patent and design applications, and restrictions on the supplier's later use of the technology. On that basis, the associated payment was characterised as involving transfer of technology and technical know-how, bringing it within royalty and fees for technical services rather than simple goods consideration. The separate question of whether a lower withholding tax rate applied under section 115A(1)(b)(BB) was not examined below and was restored for limited reconsideration. Case-Laws Income Tax Wed, 16 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=221198