https://www.taxtmi.com/caselaws?id=300613 Receipts from supply of hardware with embedded software and viewing cards/set-top boxes were treated as consideration for an integrated product, not as royalty, because no copyright rights were transferred and treaty protection prevailed over the later domestic amendment. Ancillary support, training and maintenance receipts were not fees for technical services, as the services did not make available technical knowledge or know-how to customers. Reimbursement receipts were remanded for fresh factual examination because the existence of a pure cost-to-cost pass-through and any service element had not been properly established. Interest under section 234B was held not leviable on the non-resident assessee, and eligible TDS credit was directed to be granted in accordance with law. en-us Fri, 12 Nov 2021 00:00:00 +0530 Tue, 15 Feb 2022 16:29:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300613 Receipts from supply of hardware with embedded software and viewing cards/set-top boxes were treated as consideration for an integrated product, not as royalty, because no copyright rights were transferred and treaty protection prevailed over the later domestic amendment. Ancillary support, training and maintenance receipts were not fees for technical services, as the services did not make available technical knowledge or know-how to customers. Reimbursement receipts were remanded for fresh factual examination because the existence of a pure cost-to-cost pass-through and any service element had not been properly established. Interest under section 234B was held not leviable on the non-resident assessee, and eligible TDS credit was directed to be granted in accordance with law. Case-Laws Income Tax Fri, 12 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300613