https://www.taxtmi.com/caselaws?id=280130 Payments for drawings and designs supplied by a foreign parent were treated as consideration for copyrighted articles sold on a principal-to-principal basis, not as a transfer of rights in copyright. Because the restrictive legends showed that no underlying copyright was assigned, the payment did not constitute royalty under section 9(1)(vi) or Article 12 of the India-Austria DTAA, and no tax deduction at source was required under section 195. On that basis, the demand raised under section 201 and the related interest under section 201(1A) were not sustainable. en-us Fri, 30 Apr 2010 00:00:00 +0530 Mon, 22 Apr 2019 14:50:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280130 Payments for drawings and designs supplied by a foreign parent were treated as consideration for copyrighted articles sold on a principal-to-principal basis, not as a transfer of rights in copyright. Because the restrictive legends showed that no underlying copyright was assigned, the payment did not constitute royalty under section 9(1)(vi) or Article 12 of the India-Austria DTAA, and no tax deduction at source was required under section 195. On that basis, the demand raised under section 201 and the related interest under section 201(1A) were not sustainable. Case-Laws Income Tax Fri, 30 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280130