https://www.taxtmi.com/caselaws?id=16108 The High Court held that payments made under Article III(a) of a collaboration agreement were not taxable in India as they were for the transfer of technical know-how mostly conducted outside India. The court distinguished between the transfer of know-how and its use, determining that the former did not accrue or arise in India. Relying on relevant case law, the court ruled in favor of the assessee, finding that payments for services rendered outside India did not constitute income accruing or arising in India under the Income Tax Act, 1961. en-us Mon, 16 Nov 1998 00:00:00 +0530 Tue, 01 Sep 2009 11:53:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16108 The High Court held that payments made under Article III(a) of a collaboration agreement were not taxable in India as they were for the transfer of technical know-how mostly conducted outside India. The court distinguished between the transfer of know-how and its use, determining that the former did not accrue or arise in India. Relying on relevant case law, the court ruled in favor of the assessee, finding that payments for services rendered outside India did not constitute income accruing or arising in India under the Income Tax Act, 1961. Case-Laws Income Tax Mon, 16 Nov 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16108