https://www.taxtmi.com/caselaws?id=26284 The High Court ruled in favor of the assessee in a tax liability dispute concerning a payment made to a foreign collaborator. The court held that the sum did not accrue or arise in India for tax purposes based on the collaboration agreement being initiated in Switzerland, technical documents provided there, and no business activity in India. The court upheld lower authorities' findings, citing Carborandum Co. v. CIT [1977] 108 ITR 335 (SC), and directed each party to bear their own costs. en-us Thu, 25 Jul 1985 00:00:00 +0530 Thu, 04 Feb 2010 10:36:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26284 The High Court ruled in favor of the assessee in a tax liability dispute concerning a payment made to a foreign collaborator. The court held that the sum did not accrue or arise in India for tax purposes based on the collaboration agreement being initiated in Switzerland, technical documents provided there, and no business activity in India. The court upheld lower authorities' findings, citing Carborandum Co. v. CIT [1977] 108 ITR 335 (SC), and directed each party to bear their own costs. Case-Laws Income Tax Thu, 25 Jul 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26284