https://www.taxtmi.com/caselaws?id=253583 A composite lump-sum payment for supply and installation of machinery, engineering assistance and limited know-how was treated as not constituting royalty, because the arrangement was not a mere licence for use of a patent, design or process; in any event, the more beneficial India-United Kingdom treaty definition prevailed under section 90. Interest for return-filing default was also held unsustainable where the assessee was treated as agent of the non-resident only after the relevant due dates had expired, so no representative filing obligation had yet arisen. en-us Thu, 06 Nov 2014 00:00:00 +0530 Thu, 13 Aug 2015 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253583 A composite lump-sum payment for supply and installation of machinery, engineering assistance and limited know-how was treated as not constituting royalty, because the arrangement was not a mere licence for use of a patent, design or process; in any event, the more beneficial India-United Kingdom treaty definition prevailed under section 90. Interest for return-filing default was also held unsustainable where the assessee was treated as agent of the non-resident only after the relevant due dates had expired, so no representative filing obligation had yet arisen. Case-Laws Income Tax Thu, 06 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253583