https://www.taxtmi.com/caselaws?id=178938 Payments must be characterised by their real substance, not the contractual label. On the liaison, advisory and negotiation-related services, the record showed pure service elements rather than any imparting of technical, industrial, commercial or scientific knowledge, so the amounts were not royalty and no tax was required to be deducted at source. For the remaining support services, the material was insufficient to determine whether the consideration involved secret know-how or only routine commercial assistance, so that issue was restored for fresh factual examination. en-us Fri, 03 Feb 2006 00:00:00 +0530 Thu, 21 Mar 2024 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178938 Payments must be characterised by their real substance, not the contractual label. On the liaison, advisory and negotiation-related services, the record showed pure service elements rather than any imparting of technical, industrial, commercial or scientific knowledge, so the amounts were not royalty and no tax was required to be deducted at source. For the remaining support services, the material was insufficient to determine whether the consideration involved secret know-how or only routine commercial assistance, so that issue was restored for fresh factual examination. Case-Laws Income Tax Fri, 03 Feb 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178938