https://www.taxtmi.com/caselaws?id=28344 The proposed remittances to a French collaborator for detailed engineering and furnace trials were treated as payments for technical or professional services, not royalty under the double taxation agreement. Detailed engineering was described as technical assistance to adapt furnaces to the taxpayer's plant, and furnace trials were described as technical testing services carried out in France to make electrodes marketable internationally. As the payments did not involve use of patents, designs, know-how, or other rights covered by the royalty article, they were not taxable in India on that basis, and the authorities were not justified in insisting on deduction or payment of income tax as a condition for issuing the no-objection certificate. en-us Wed, 17 Mar 1982 00:00:00 +0530 Sat, 20 Feb 2010 18:05:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28344 The proposed remittances to a French collaborator for detailed engineering and furnace trials were treated as payments for technical or professional services, not royalty under the double taxation agreement. Detailed engineering was described as technical assistance to adapt furnaces to the taxpayer's plant, and furnace trials were described as technical testing services carried out in France to make electrodes marketable internationally. As the payments did not involve use of patents, designs, know-how, or other rights covered by the royalty article, they were not taxable in India on that basis, and the authorities were not justified in insisting on deduction or payment of income tax as a condition for issuing the no-objection certificate. Case-Laws Income Tax Wed, 17 Mar 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28344