https://www.taxtmi.com/caselaws?id=258621 Under a technical assistance and know-how agreement, the receipt was held to be separable into distinct treaty components rather than a single composite royalty payment. Only the portion attributable to transfer of know-how fell within royalty under Article 12, while consideration for training and technical services remained separate. The technical service component could not be taxed as business profits under Article 7 because the enterprise had no permanent establishment in India for the relevant years. Article 22 was unavailable because the receipts were specifically covered by Articles 12 and 7, leaving no scope for treatment as miscellaneous income. en-us Tue, 12 Jun 2012 00:00:00 +0530 Thu, 21 May 2026 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258621 Under a technical assistance and know-how agreement, the receipt was held to be separable into distinct treaty components rather than a single composite royalty payment. Only the portion attributable to transfer of know-how fell within royalty under Article 12, while consideration for training and technical services remained separate. The technical service component could not be taxed as business profits under Article 7 because the enterprise had no permanent establishment in India for the relevant years. Article 22 was unavailable because the receipts were specifically covered by Articles 12 and 7, leaving no scope for treatment as miscellaneous income. Case-Laws Income Tax Tue, 12 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258621