https://www.taxtmi.com/caselaws?id=254045 Consideration receivable under the agreements was treated as taxable only if it constituted royalty; the Court held the issue was already covered by its earlier decision involving the same assessee for an earlier assessment year. Applying that prior ruling, it accepted that the present reference was governed on identical facts and legal question, so the receipts fell within the Double Taxation Avoidance Agreement as industrial or commercial profits and were not taxable in India in the absence of a permanent establishment. The referred question was answered in favour of the assessee and against the Revenue. en-us Thu, 18 Sep 2014 00:00:00 +0530 Thu, 11 Dec 2014 05:56:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=254045 Consideration receivable under the agreements was treated as taxable only if it constituted royalty; the Court held the issue was already covered by its earlier decision involving the same assessee for an earlier assessment year. Applying that prior ruling, it accepted that the present reference was governed on identical facts and legal question, so the receipts fell within the Double Taxation Avoidance Agreement as industrial or commercial profits and were not taxable in India in the absence of a permanent establishment. The referred question was answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Thu, 18 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254045