https://www.taxtmi.com/caselaws?id=10132 The High Court dismissed the appeal, ruling in favor of the foreign company, as the payment made to the foreign company was considered technical know-how fees and not royalty, thus subject to a tax rate of 20% as per the Double Taxation Avoidance Agreement with Germany. The court emphasized that the appeal did not involve any substantial legal issue but rather challenged factual findings made by lower appellate authorities, which parties cannot appeal against alone. en-us Thu, 15 Jul 2004 00:00:00 +0530 Wed, 08 Jul 2009 07:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10132 The High Court dismissed the appeal, ruling in favor of the foreign company, as the payment made to the foreign company was considered technical know-how fees and not royalty, thus subject to a tax rate of 20% as per the Double Taxation Avoidance Agreement with Germany. The court emphasized that the appeal did not involve any substantial legal issue but rather challenged factual findings made by lower appellate authorities, which parties cannot appeal against alone. Case-Laws Income Tax Thu, 15 Jul 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10132