https://www.taxtmi.com/caselaws?id=307488 Lease rentals for alloy supplied to refurbish bushings were held not to constitute royalty under the Income-tax Act or the India-USA DTAA because the assessee only provided platinum-rhodium alloy for use in refurbishment and did not transfer any right to use the bushing design or related technology. Royalty requires payment to the person holding the relevant exclusive right, and that condition was absent on the stated facts. The receipt was therefore treated as consideration for alloy supply rather than royalty, and the addition made on that basis was directed to be deleted. en-us Mon, 04 Oct 2021 00:00:00 +0530 Mon, 17 Apr 2023 21:15:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307488 Lease rentals for alloy supplied to refurbish bushings were held not to constitute royalty under the Income-tax Act or the India-USA DTAA because the assessee only provided platinum-rhodium alloy for use in refurbishment and did not transfer any right to use the bushing design or related technology. Royalty requires payment to the person holding the relevant exclusive right, and that condition was absent on the stated facts. The receipt was therefore treated as consideration for alloy supply rather than royalty, and the addition made on that basis was directed to be deleted. Case-Laws Income Tax Mon, 04 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307488