https://www.taxtmi.com/caselaws?id=12172 The dominant issue was whether consideration under a composite offshore supply contract could be bifurcated so as to treat a portion as "royalty" under Explanation 2 to s. 9(1) of the Income-tax Act, 1961, thereby deeming income to accrue or arise in India. The HC held that where the consideration covered integrated obligations for design and for engineering, manufacturing, shop testing, and packing up to f.o.b. port of embarkation, it was not feasible to apportion the amount towards design separately; consequently, any transfer of design, if at all, did not fall within the scope of "royalty" under the Explanation, following the principle in a DB decision of another HC. The appeal was dismissed for absence of any substantial question of law. en-us Fri, 21 Dec 2001 00:00:00 +0530 Tue, 23 Dec 2025 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12172 The dominant issue was whether consideration under a composite offshore supply contract could be bifurcated so as to treat a portion as "royalty" under Explanation 2 to s. 9(1) of the Income-tax Act, 1961, thereby deeming income to accrue or arise in India. The HC held that where the consideration covered integrated obligations for design and for engineering, manufacturing, shop testing, and packing up to f.o.b. port of embarkation, it was not feasible to apportion the amount towards design separately; consequently, any transfer of design, if at all, did not fall within the scope of "royalty" under the Explanation, following the principle in a DB decision of another HC. The appeal was dismissed for absence of any substantial question of law. Case-Laws Income Tax Fri, 21 Dec 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12172