https://www.taxtmi.com/caselaws?id=253583 The High Court upheld the Tribunal's decision, dismissing the appeals and ruling in favor of the respondent against the Revenue. It was held that the payments made by the respondent to the foreign company were not considered royalty under the Income Tax Act and the Double Tax Avoidance Agreement. Additionally, the respondent was not liable for interest under Section 139(8) of the Act. The Court concluded that the transactions were part of a comprehensive contract for the supply of machinery and know-how, not constituting royalty payments. 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 The High Court upheld the Tribunal's decision, dismissing the appeals and ruling in favor of the respondent against the Revenue. It was held that the payments made by the respondent to the foreign company were not considered royalty under the Income Tax Act and the Double Tax Avoidance Agreement. Additionally, the respondent was not liable for interest under Section 139(8) of the Act. The Court concluded that the transactions were part of a comprehensive contract for the supply of machinery and know-how, not constituting royalty payments. Case-Laws Income Tax Thu, 06 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253583