https://www.taxtmi.com/caselaws?id=465394 Royalty received by a non-resident from OEMs outside India for licensing patents used in manufacturing subscriber units and infrastructure equipment outside India was held not taxable in India. The tribunal noted that the OEMs were not shown to carry on business in India, to use the patented rights in business carried on in India, or to exploit the patents for income from a source in India. Applying coordinate bench and jurisdictional precedents, it held that the royalty deeming provision did not apply on these facts, and the addition was deleted. en-us Thu, 14 Nov 2024 00:00:00 +0530 Fri, 19 Dec 2025 21:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465394 Royalty received by a non-resident from OEMs outside India for licensing patents used in manufacturing subscriber units and infrastructure equipment outside India was held not taxable in India. The tribunal noted that the OEMs were not shown to carry on business in India, to use the patented rights in business carried on in India, or to exploit the patents for income from a source in India. Applying coordinate bench and jurisdictional precedents, it held that the royalty deeming provision did not apply on these facts, and the addition was deleted. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465394