https://www.taxtmi.com/caselaws?id=328838 A composite management and administrative services agreement was examined under the royalty definition in section 9(1)(vi) of the Income-tax Act and Article 13 of the Indo-UK DTAA. The note explains that where the contract includes both ordinary services and elements that may amount to imparting industrial, commercial or scientific experience, the tax character depends on the substance of the arrangement and the available apportionment material. Because no reliable breakup of consideration or supporting details was furnished, the principal nature of the agreement was applied to the whole receipt, and the amount was treated as royalty rather than business income. en-us Fri, 29 Apr 2016 00:00:00 +0530 Wed, 15 Jun 2016 18:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328838 A composite management and administrative services agreement was examined under the royalty definition in section 9(1)(vi) of the Income-tax Act and Article 13 of the Indo-UK DTAA. The note explains that where the contract includes both ordinary services and elements that may amount to imparting industrial, commercial or scientific experience, the tax character depends on the substance of the arrangement and the available apportionment material. Because no reliable breakup of consideration or supporting details was furnished, the principal nature of the agreement was applied to the whole receipt, and the amount was treated as royalty rather than business income. Case-Laws Income Tax Fri, 29 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328838