https://www.taxtmi.com/caselaws?id=331625 Delay in filing the appeals was condoned because the assessee showed a bona fide mistake in first challenging a common order and later filing separate appeals, with no negligence or deliberate inaction. Payments for project-specific architectural drawings, designs and plans made to a non-resident without a permanent establishment in India were held not to be royalty or fees for included services, as there was no transfer of technical know-how, no making available of technical knowledge, skill or process, and the drawings remained the foreign entity's property. Treaty protection prevailed, so no tax deduction at source was required and the withholding demand was set aside. en-us Fri, 29 Jul 2016 00:00:00 +0530 Mon, 06 Feb 2017 14:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331625 Delay in filing the appeals was condoned because the assessee showed a bona fide mistake in first challenging a common order and later filing separate appeals, with no negligence or deliberate inaction. Payments for project-specific architectural drawings, designs and plans made to a non-resident without a permanent establishment in India were held not to be royalty or fees for included services, as there was no transfer of technical know-how, no making available of technical knowledge, skill or process, and the drawings remained the foreign entity's property. Treaty protection prevailed, so no tax deduction at source was required and the withholding demand was set aside. Case-Laws Income Tax Fri, 29 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331625