https://www.taxtmi.com/caselaws?id=38627 A technical collaboration fee was held taxable in India to the extent attributable to India-related assistance under the agreement. The court treated the contractual obligations as inseparable: the consideration covered not only disclosure of know-how in Italy but also practical assistance to the Indian company in using, adjusting, and improving the processes in India. On that basis, apportionment of the fee was accepted, and the portion referable to the Indian component was treated as income accruing or arising in the taxable territories. en-us Thu, 11 Nov 1976 00:00:00 +0530 Wed, 07 Apr 2010 17:10:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38627 A technical collaboration fee was held taxable in India to the extent attributable to India-related assistance under the agreement. The court treated the contractual obligations as inseparable: the consideration covered not only disclosure of know-how in Italy but also practical assistance to the Indian company in using, adjusting, and improving the processes in India. On that basis, apportionment of the fee was accepted, and the portion referable to the Indian component was treated as income accruing or arising in the taxable territories. Case-Laws Income Tax Thu, 11 Nov 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38627