https://www.taxtmi.com/caselaws?id=5577 An agreement for transfer of trade secrets and technical assistance was treated as having two interdependent parts, but only the trade secret consideration was in issue. The taxability of the technical assistance payment was not disputed; the legal question was whether the separate amount paid for sale of trade secrets could be regarded as income earned in India. Because the agreement expressly stated that the sale took place in Japan and no basis existed to attribute that consideration to India, the amount was held not taxable in India. en-us Thu, 26 Sep 1996 00:00:00 +0530 Fri, 31 Aug 2018 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5577 An agreement for transfer of trade secrets and technical assistance was treated as having two interdependent parts, but only the trade secret consideration was in issue. The taxability of the technical assistance payment was not disputed; the legal question was whether the separate amount paid for sale of trade secrets could be regarded as income earned in India. Because the agreement expressly stated that the sale took place in Japan and no basis existed to attribute that consideration to India, the amount was held not taxable in India. Case-Laws Income Tax Thu, 26 Sep 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5577