https://www.taxtmi.com/caselaws?id=237178 The Tribunal upheld the orders of the CIT(A), dismissing the appeals of the assessee and taxing the payments as royalty in both assessment years. The payments were deemed taxable as royalty under section 9(1)(vi) of the Income Tax Act and Article 12 of the DTAA between India and Germany. The Tribunal emphasized that the nature of the agreement indicated that the payments were for the use of technology and trademarks, not for their transfer, and therefore taxable in India. en-us Fri, 13 Sep 2013 00:00:00 +0530 Fri, 20 Sep 2013 09:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237178 The Tribunal upheld the orders of the CIT(A), dismissing the appeals of the assessee and taxing the payments as royalty in both assessment years. The payments were deemed taxable as royalty under section 9(1)(vi) of the Income Tax Act and Article 12 of the DTAA between India and Germany. The Tribunal emphasized that the nature of the agreement indicated that the payments were for the use of technology and trademarks, not for their transfer, and therefore taxable in India. Case-Laws Income Tax Fri, 13 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237178