https://www.taxtmi.com/caselaws?id=369641 Payment for technical assistance to design and improve an existing engine component was held not to be royalty, because the Austrian consultant merely rendered technical services and the assessee retained ownership of the engine design and deliverables. Standard confidentiality and intellectual property protection clauses in the agreement were treated as protective terms only, insufficient to create a licence or a right to use intellectual property. The payment was therefore characterised as fees for technical services rather than royalty, and the Revenue's challenge failed. en-us Wed, 24 Oct 2018 00:00:00 +0530 Sat, 19 Oct 2019 15:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369641 Payment for technical assistance to design and improve an existing engine component was held not to be royalty, because the Austrian consultant merely rendered technical services and the assessee retained ownership of the engine design and deliverables. Standard confidentiality and intellectual property protection clauses in the agreement were treated as protective terms only, insufficient to create a licence or a right to use intellectual property. The payment was therefore characterised as fees for technical services rather than royalty, and the Revenue's challenge failed. Case-Laws Income Tax Wed, 24 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369641