https://www.taxtmi.com/caselaws?id=22662 HC held that payments made by the resident assessee to the non-resident for drawings and designs constituted consideration for an outright transfer of property and not "royalty" under Explanation 2 to section 9(1)(vi) or article XIII of the India-U.K. DTAA. Emphasizing that "royalty" requires the owner to retain proprietary rights and merely permit use or grant a right to use, the HC found that the importation of designs and drawings, approved under the import policy and by the RBI, amounted to a complete sale with no residual rights retained by the foreign company. Accordingly, the Tribunal's view was upheld and the question was answered in favour of the assessee. en-us Thu, 13 Dec 1990 00:00:00 +0530 Fri, 05 Dec 2025 18:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22662 HC held that payments made by the resident assessee to the non-resident for drawings and designs constituted consideration for an outright transfer of property and not "royalty" under Explanation 2 to section 9(1)(vi) or article XIII of the India-U.K. DTAA. Emphasizing that "royalty" requires the owner to retain proprietary rights and merely permit use or grant a right to use, the HC found that the importation of designs and drawings, approved under the import policy and by the RBI, amounted to a complete sale with no residual rights retained by the foreign company. Accordingly, the Tribunal's view was upheld and the question was answered in favour of the assessee. Case-Laws Income Tax Thu, 13 Dec 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22662