https://www.taxtmi.com/caselaws?id=406558 Payments made to a foreign research corporation under a collaborative joint research agreement were treated as cost reimbursement for shared research work, with both parties retaining rights in the research results. The revenue failed to show that the assessee obtained a right to use intellectual property in return for royalty, or that the remittance fell within the statutory meaning of royalty under section 9(1)(vi) of the Income-tax Act, 1961. The payments were therefore not royalty, no tax was deductible under section 195 on that basis, and the interest charged under section 201(1A) was unsustainable. en-us Mon, 05 Apr 2021 00:00:00 +0530 Tue, 09 Aug 2022 17:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406558 Payments made to a foreign research corporation under a collaborative joint research agreement were treated as cost reimbursement for shared research work, with both parties retaining rights in the research results. The revenue failed to show that the assessee obtained a right to use intellectual property in return for royalty, or that the remittance fell within the statutory meaning of royalty under section 9(1)(vi) of the Income-tax Act, 1961. The payments were therefore not royalty, no tax was deductible under section 195 on that basis, and the interest charged under section 201(1A) was unsustainable. Case-Laws Income Tax Mon, 05 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406558