https://www.taxtmi.com/caselaws?id=397052 The High Court ruled in favor of the revenue, finding that the payments made by the assessee cannot be treated as royalty, thereby negating the liability for tax deduction under Section 195 of the Act and ruling out the applicability of Section 40(a) of the Act. The Court acknowledged the revenue's submission and directed the assessing authority to pass an order under Section 260(1A) of the Act based on the outcome of the assessee's potential appeal before the Apex Court. If the assessee loses the appeal, the assessing authority was instructed to consider the application of Article 24(4) of the DTAA between India and the Netherlands. en-us Tue, 16 Jun 2020 00:00:00 +0530 Thu, 30 Jul 2020 18:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397052 The High Court ruled in favor of the revenue, finding that the payments made by the assessee cannot be treated as royalty, thereby negating the liability for tax deduction under Section 195 of the Act and ruling out the applicability of Section 40(a) of the Act. The Court acknowledged the revenue's submission and directed the assessing authority to pass an order under Section 260(1A) of the Act based on the outcome of the assessee's potential appeal before the Apex Court. If the assessee loses the appeal, the assessing authority was instructed to consider the application of Article 24(4) of the DTAA between India and the Netherlands. Case-Laws Income Tax Tue, 16 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397052