https://www.taxtmi.com/caselaws?id=193368 Payments made to licensors were analysed under section 9(1)(vi) of the Income-tax Act and Article 12 of the Indo-Finland DTAA for royalty characterisation. The Tribunal had applied earlier binding decisions of the same High Court on similar payments, and that approach was consistent with the later precedent interpreting the same provision in the treaty context. On that basis, the Tribunal's view was treated as sound and no substantial question of law arose under section 260A; the Revenue's appeals therefore failed. en-us Mon, 19 Dec 2016 00:00:00 +0530 Wed, 26 Jul 2017 10:29:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193368 Payments made to licensors were analysed under section 9(1)(vi) of the Income-tax Act and Article 12 of the Indo-Finland DTAA for royalty characterisation. The Tribunal had applied earlier binding decisions of the same High Court on similar payments, and that approach was consistent with the later precedent interpreting the same provision in the treaty context. On that basis, the Tribunal's view was treated as sound and no substantial question of law arose under section 260A; the Revenue's appeals therefore failed. Case-Laws Income Tax Mon, 19 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193368