https://www.taxtmi.com/caselaws?id=257428 Royalty taxability turned on whether payments for CDMA handsets and infrastructure equipment were linked to patented technology used in India or required further factual verification on OEM presence, India-specific features, and the relevant source of use. The Tribunal remitted that issue to the Assessing Officer for fresh examination. On the BREW Operator and Carrier Agreement receipts, it held that the licence covered use of a copyrighted article for internal business purposes and did not transfer any copyright rights, so the receipts were not royalty. The addition was deleted on that ground. en-us Fri, 20 Feb 2015 00:00:00 +0530 Sun, 03 May 2015 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257428 Royalty taxability turned on whether payments for CDMA handsets and infrastructure equipment were linked to patented technology used in India or required further factual verification on OEM presence, India-specific features, and the relevant source of use. The Tribunal remitted that issue to the Assessing Officer for fresh examination. On the BREW Operator and Carrier Agreement receipts, it held that the licence covered use of a copyrighted article for internal business purposes and did not transfer any copyright rights, so the receipts were not royalty. The addition was deleted on that ground. Case-Laws Income Tax Fri, 20 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257428