https://www.taxtmi.com/caselaws?id=13123 Royalty income under the agreement signed on 10 December 1981 qualified for the concessional 30% tax rate under article 13(2) of the India-U.K. tax treaty because the contract was signed after the Convention came into force on 23 November 1981. The court treated the 1981 agreement as a fresh contract, not a mere extension of the earlier 1971 arrangement, since its royalty structure and contractual conditions were materially different. The fact that it was made effective from 1 January 1980 did not change its legal character as an agreement signed after the treaty's commencement. The Revenue's attempt to apply the higher rate was rejected. en-us Thu, 30 Aug 2001 00:00:00 +0530 Tue, 26 May 2009 15:13:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13123 Royalty income under the agreement signed on 10 December 1981 qualified for the concessional 30% tax rate under article 13(2) of the India-U.K. tax treaty because the contract was signed after the Convention came into force on 23 November 1981. The court treated the 1981 agreement as a fresh contract, not a mere extension of the earlier 1971 arrangement, since its royalty structure and contractual conditions were materially different. The fact that it was made effective from 1 January 1980 did not change its legal character as an agreement signed after the treaty's commencement. The Revenue's attempt to apply the higher rate was rejected. Case-Laws Income Tax Thu, 30 Aug 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13123