https://www.taxtmi.com/circulars?id=9351 Engineering fees to non resident collaborators must be characterised as either royalty or fees for technical or engineering services, because the characterisation determines source and allocation for tax. The Board instructs tax officers to examine the basic nature of such receipts in pending appeals and make representations to ensure assessment under the correct head. Where collaboration agreements pre date amendments and were government approved, officers must determine whether the fees are in the nature of royalty and raise the issue before appellate authorities if no finding exists. en-us Tue, 29 Jul 1980 00:00:00 +0530 Sat, 04 Jun 2011 13:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=9351 Engineering fees to non resident collaborators must be characterised as either royalty or fees for technical or engineering services, because the characterisation determines source and allocation for tax. The Board instructs tax officers to examine the basic nature of such receipts in pending appeals and make representations to ensure assessment under the correct head. Where collaboration agreements pre date amendments and were government approved, officers must determine whether the fees are in the nature of royalty and raise the issue before appellate authorities if no finding exists. Circulars Income Tax Tue, 29 Jul 1980 00:00:00 +0530 https://www.taxtmi.com/circulars?id=9351