https://www.taxtmi.com/caselaws?id=465411 Royalty received from non-resident OEMs outside India, with no permanent establishment in India, was held not taxable under section 9(1)(vi)(c) where the manufacturing activity and use of the patents occurred outside India and the Revenue failed to establish taxable accrual or presence in India for the years under appeal. The ITAT Delhi followed coordinate bench rulings in the assessee's earlier and later years on identical facts, and found the impugned royalty addition unsustainable. Issues relating to reopening, approval, interest, and penalty were either not argued or were merely consequential and did not require separate adjudication. en-us Thu, 29 Aug 2024 00:00:00 +0530 Sat, 20 Dec 2025 22:28:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465411 Royalty received from non-resident OEMs outside India, with no permanent establishment in India, was held not taxable under section 9(1)(vi)(c) where the manufacturing activity and use of the patents occurred outside India and the Revenue failed to establish taxable accrual or presence in India for the years under appeal. The ITAT Delhi followed coordinate bench rulings in the assessee's earlier and later years on identical facts, and found the impugned royalty addition unsustainable. Issues relating to reopening, approval, interest, and penalty were either not argued or were merely consequential and did not require separate adjudication. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465411