https://www.taxtmi.com/caselaws?id=753611 Payments for preparation of technical documentation, working drawings, testing models and related technical work in Russia were not treated as royalty under Section 9 of the Income-tax Act, 1961 because the foreign entity did not impart technical information, rights, or control over the material to the assessee. The work product was to remain and be used in Russia, and the assessee did not receive the kind of knowledge, experience, or rights that constitute royalty. The final product was characterised as a capital asset rather than royalty, so tax deduction at 20% was not attracted. en-us Thu, 25 Apr 2024 00:00:00 +0530 Thu, 06 Jun 2024 08:22:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753611 Payments for preparation of technical documentation, working drawings, testing models and related technical work in Russia were not treated as royalty under Section 9 of the Income-tax Act, 1961 because the foreign entity did not impart technical information, rights, or control over the material to the assessee. The work product was to remain and be used in Russia, and the assessee did not receive the kind of knowledge, experience, or rights that constitute royalty. The final product was characterised as a capital asset rather than royalty, so tax deduction at 20% was not attracted. Case-Laws Income Tax Thu, 25 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753611