https://www.taxtmi.com/highlights?id=98023 Consideration for project-specific designs, drawings and related deliverables was held to be an outright transfer of those documents and the associated project intellectual property, not payment for the use of, or right to use, a design. Article 12(3) of the India-UAE DTAA was interpreted as covering only use-right payments, so sale or transfer receipts fell outside royalty. Because treaty protection was claimed, the wider domestic definition of royalty could not be invoked. The receipt was therefore not taxable as royalty in India and the contrary assessment was set aside. en-us Tue, 24 Mar 2026 08:12:27 +0530 Tue, 24 Mar 2026 08:12:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98023 Consideration for project-specific designs, drawings and related deliverables was held to be an outright transfer of those documents and the associated project intellectual property, not payment for the use of, or right to use, a design. Article 12(3) of the India-UAE DTAA was interpreted as covering only use-right payments, so sale or transfer receipts fell outside royalty. Because treaty protection was claimed, the wider domestic definition of royalty could not be invoked. The receipt was therefore not taxable as royalty in India and the contrary assessment was set aside. Highlights Income Tax Tue, 24 Mar 2026 08:12:27 +0530 https://www.taxtmi.com/highlights?id=98023