https://www.taxtmi.com/caselaws?id=25073 The court affirmed that payments made by an Indian company to a non-resident were correctly classified as 50% royalty and 50% technical service fees. The estimate made by the Commissioner of Income-tax regarding this proportion was deemed reasonable. Additionally, the court upheld that 80% of the royalty income was taxable in India. The court ruled in favor of the Revenue, concluding that the payments classified as royalty were appropriately identified as such. The second issue raised was not addressed as the assessee did not pursue it further. en-us Tue, 22 Dec 1987 00:00:00 +0530 Mon, 25 Jan 2010 11:59:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25073 The court affirmed that payments made by an Indian company to a non-resident were correctly classified as 50% royalty and 50% technical service fees. The estimate made by the Commissioner of Income-tax regarding this proportion was deemed reasonable. Additionally, the court upheld that 80% of the royalty income was taxable in India. The court ruled in favor of the Revenue, concluding that the payments classified as royalty were appropriately identified as such. The second issue raised was not addressed as the assessee did not pursue it further. Case-Laws Income Tax Tue, 22 Dec 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25073