https://www.taxtmi.com/caselaws?id=34811 Composite technology-transfer arrangements are taxable in India as royalty or fees for technical services where the substance is the transfer of know-how and the making available of technical knowledge to the Indian enterprise, even if technical documentation is supplied offshore. The transfer of know-how and the right to use technical documentation was treated as royalty under the Act and the India-USA treaty. By contrast, an outright transfer of ownership in tread and side-wall designs or patterns was not royalty to that extent, although related product-development payments linked to know-how were taxable. Consultancy, assistance and training fees were also taxable as included services and technical services because they made technical knowledge available for independent use. en-us Wed, 28 Oct 2009 00:00:00 +0530 Fri, 26 Mar 2010 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34811 Composite technology-transfer arrangements are taxable in India as royalty or fees for technical services where the substance is the transfer of know-how and the making available of technical knowledge to the Indian enterprise, even if technical documentation is supplied offshore. The transfer of know-how and the right to use technical documentation was treated as royalty under the Act and the India-USA treaty. By contrast, an outright transfer of ownership in tread and side-wall designs or patterns was not royalty to that extent, although related product-development payments linked to know-how were taxable. Consultancy, assistance and training fees were also taxable as included services and technical services because they made technical knowledge available for independent use. Case-Laws Income Tax Wed, 28 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34811