https://www.taxtmi.com/caselaws?id=15279 HC held that payments made by the assessee to a non-resident for design and engineering of tailor-made machinery did not constitute "royalty" under section 9(1)(vi) or 9(1)(vii). The court found no transfer or licence of any patent, invention, model or design and the information supplied was incidental to manufacture and maintenance. Consequently, the amounts formed part of the contract price and did not accrue or arise in India as income of the foreign supplier. Decision for the assessee against the Revenue. en-us Thu, 07 Oct 1999 00:00:00 +0530 Wed, 08 Oct 2025 19:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15279 HC held that payments made by the assessee to a non-resident for design and engineering of tailor-made machinery did not constitute "royalty" under section 9(1)(vi) or 9(1)(vii). The court found no transfer or licence of any patent, invention, model or design and the information supplied was incidental to manufacture and maintenance. Consequently, the amounts formed part of the contract price and did not accrue or arise in India as income of the foreign supplier. Decision for the assessee against the Revenue. Case-Laws Income Tax Thu, 07 Oct 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15279