https://www.taxtmi.com/caselaws?id=764797 Receipts from background screening services were held not to constitute royalty under section 9(1)(vi) because the reports only conveyed factual verification findings and did not grant any right to use copyright, database, technical know-how, or other protected intellectual property, nor did they make available technical knowledge, skill, or experience. The transfer pricing/addition on this count was deleted. The challenge to initiation of penalty under section 270A was rejected as premature because no final penalty determination was under challenge at that stage. en-us Thu, 14 Nov 2024 00:00:00 +0530 Sat, 18 Jan 2025 08:47:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764797 Receipts from background screening services were held not to constitute royalty under section 9(1)(vi) because the reports only conveyed factual verification findings and did not grant any right to use copyright, database, technical know-how, or other protected intellectual property, nor did they make available technical knowledge, skill, or experience. The transfer pricing/addition on this count was deleted. The challenge to initiation of penalty under section 270A was rejected as premature because no final penalty determination was under challenge at that stage. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764797