https://www.taxtmi.com/highlights?id=103047 Outright acquisition of trademark ownership for lump-sum consideration constitutes acquisition of a capital asset rather than payment for the use of intellectual property or continuing royalty. A foreign remittance for such transfer does not by itself create a tax deduction obligation under section 195; withholding applies only where the remitted sum is chargeable to tax in India. Where the assignment agreement, transferred rights, valuation, commercial terms, ownership evidence and recipient's tax residency certificate establish an ownership transfer, the payer cannot be treated as in default for non-deduction of tax. Demands for tax and consequential interest under sections 201(1) and 201(1A) were deleted. en-us Tue, 25 Aug 2026 08:34:03 +0530 Tue, 25 Aug 2026 08:34:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103047 Outright acquisition of trademark ownership for lump-sum consideration constitutes acquisition of a capital asset rather than payment for the use of intellectual property or continuing royalty. A foreign remittance for such transfer does not by itself create a tax deduction obligation under section 195; withholding applies only where the remitted sum is chargeable to tax in India. Where the assignment agreement, transferred rights, valuation, commercial terms, ownership evidence and recipient's tax residency certificate establish an ownership transfer, the payer cannot be treated as in default for non-deduction of tax. Demands for tax and consequential interest under sections 201(1) and 201(1A) were deleted. Highlights Income Tax Tue, 25 Aug 2026 08:34:03 +0530 https://www.taxtmi.com/highlights?id=103047