https://www.taxtmi.com/caselaws?id=181128 An outright sale of engineering drawings and designs under a composite purchase arrangement was held not to be royalty or fees for included services under the India-US tax treaty, because the payment was for transfer of the product and not a licence to use property or a contingent payment for rights in property. The associated engineering services were treated as ancillary and subsidiary to the sale, and did not amount to standalone technical services or make available technical knowledge. As the receipts were not chargeable to tax in India under Article 12, tax deducted at source on the remittance was refundable, subject to the prescribed refund procedure and return filing requirements. en-us Wed, 29 Aug 2001 00:00:00 +0530 Thu, 07 Apr 2016 18:29:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181128 An outright sale of engineering drawings and designs under a composite purchase arrangement was held not to be royalty or fees for included services under the India-US tax treaty, because the payment was for transfer of the product and not a licence to use property or a contingent payment for rights in property. The associated engineering services were treated as ancillary and subsidiary to the sale, and did not amount to standalone technical services or make available technical knowledge. As the receipts were not chargeable to tax in India under Article 12, tax deducted at source on the remittance was refundable, subject to the prescribed refund procedure and return filing requirements. Case-Laws Income Tax Wed, 29 Aug 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181128