https://www.taxtmi.com/caselaws?id=466676 Payments for software supplied under a restricted end-user licence, without transfer of copyright, are not royalty under the Act or the treaty. A consortium arrangement does not constitute an association of persons where the parties have separate scopes of work, separate billing, no common management, no profit or loss sharing, and only contractual joint liability. Compensation embedded in an arbitral award for delayed payment retains its compensatory character up to the date of the award and is not taxed as interest for that period. Transfer pricing adjustments must be made under the prescribed arm's length method and cannot rest on an ad hoc mark-up or reporting mismatch. Royalty and fees for technical services are taxable on receipt basis under the treaty. en-us Fri, 07 Jun 2024 00:00:00 +0530 Mon, 16 Feb 2026 20:10:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466676 Payments for software supplied under a restricted end-user licence, without transfer of copyright, are not royalty under the Act or the treaty. A consortium arrangement does not constitute an association of persons where the parties have separate scopes of work, separate billing, no common management, no profit or loss sharing, and only contractual joint liability. Compensation embedded in an arbitral award for delayed payment retains its compensatory character up to the date of the award and is not taxed as interest for that period. Transfer pricing adjustments must be made under the prescribed arm's length method and cannot rest on an ad hoc mark-up or reporting mismatch. Royalty and fees for technical services are taxable on receipt basis under the treaty. Case-Laws Income Tax Fri, 07 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466676