https://www.taxtmi.com/caselaws?id=788511 Consideration for preparing and supplying project-specific bridge designs, drawings, reports and related deliverables was treated as payment for development and transfer of specific work product, not for the use of or right to use an existing design. Because the agreement provided that the deliverables would vest in the client and the remuneration was a lump sum for agreed outputs, the payment did not fall within royalty under Article 12(3) of the India-UAE DTAA. The domestic royalty deeming provision in section 9(1)(vi) could not override the more favourable treaty position, so the receipts were not taxable as royalty and the addition was unsustainable. en-us Fri, 13 Mar 2026 00:00:00 +0530 Tue, 24 Mar 2026 08:12:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788511 Consideration for preparing and supplying project-specific bridge designs, drawings, reports and related deliverables was treated as payment for development and transfer of specific work product, not for the use of or right to use an existing design. Because the agreement provided that the deliverables would vest in the client and the remuneration was a lump sum for agreed outputs, the payment did not fall within royalty under Article 12(3) of the India-UAE DTAA. The domestic royalty deeming provision in section 9(1)(vi) could not override the more favourable treaty position, so the receipts were not taxable as royalty and the addition was unsustainable. Case-Laws Income Tax Fri, 13 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788511