https://www.taxtmi.com/caselaws?id=791856 Royalty on export sales was examined for taxability in India under section 9(1)(vi)(b), with the analysis focusing on whether the source of income lay outside India and on the distinction between the source of income and the source of receipt; the matter required fresh fact-finding on where contracts were signed and whether the receipts were taxed elsewhere. Management support fees were treated separately from royalty and licensing arrangements and, following the assessee's own prior year ruling, were not regarded as fees for technical services. The Dispute Resolution Panel's direction for further verification of expense reimbursement was held to exceed the scope of section 144C(8) and was deleted. en-us Wed, 13 May 2026 00:00:00 +0530 Tue, 19 May 2026 08:18:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791856 Royalty on export sales was examined for taxability in India under section 9(1)(vi)(b), with the analysis focusing on whether the source of income lay outside India and on the distinction between the source of income and the source of receipt; the matter required fresh fact-finding on where contracts were signed and whether the receipts were taxed elsewhere. Management support fees were treated separately from royalty and licensing arrangements and, following the assessee's own prior year ruling, were not regarded as fees for technical services. The Dispute Resolution Panel's direction for further verification of expense reimbursement was held to exceed the scope of section 144C(8) and was deleted. Case-Laws Income Tax Wed, 13 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791856