https://www.taxtmi.com/caselaws?id=343810 Consideration paid for sharing validated standard operating procedures, database access and related support was treated as royalty because the SOPs constituted information concerning industrial, commercial or scientific experience under the India-Germany tax treaty. The database and software support were incidental to the principal transfer of know-how. The absence of a permanent establishment was held irrelevant to royalty taxation, since PE status matters to business profits, not royalty income. As the payment was taxable in India as royalty, the payer was required to deduct tax at source and was rightly treated as an assessee in default for non-deduction. en-us Thu, 01 Jun 2017 00:00:00 +0530 Sat, 18 Nov 2017 18:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343810 Consideration paid for sharing validated standard operating procedures, database access and related support was treated as royalty because the SOPs constituted information concerning industrial, commercial or scientific experience under the India-Germany tax treaty. The database and software support were incidental to the principal transfer of know-how. The absence of a permanent establishment was held irrelevant to royalty taxation, since PE status matters to business profits, not royalty income. As the payment was taxable in India as royalty, the payer was required to deduct tax at source and was rightly treated as an assessee in default for non-deduction. Case-Laws Income Tax Thu, 01 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343810