https://www.taxtmi.com/caselaws?id=800466 Under the India-Germany DTAA, royalties and fees for technical services are taxable on receipt rather than accrual where that treatment has consistently applied. Standard software supplied under restricted, non-exclusive, non-transferable licences without copyright exploitation rights does not generate royalty income. A consortium is not an association of persons where members perform separately identifiable work, invoice independently, retain separate profits and losses, and lack common management or a common income-earning design; joint customer liability alone is insufficient. Offshore goods-supply income is not chargeable in India under the treaty protocol. Transfer-pricing adjustments require prescribed methods and transaction analysis; an unexplained flat mark-up is unsustainable. en-us Tue, 08 Sep 2026 00:00:00 +0530 Wed, 07 Oct 2026 08:26:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800466 Under the India-Germany DTAA, royalties and fees for technical services are taxable on receipt rather than accrual where that treatment has consistently applied. Standard software supplied under restricted, non-exclusive, non-transferable licences without copyright exploitation rights does not generate royalty income. A consortium is not an association of persons where members perform separately identifiable work, invoice independently, retain separate profits and losses, and lack common management or a common income-earning design; joint customer liability alone is insufficient. Offshore goods-supply income is not chargeable in India under the treaty protocol. Transfer-pricing adjustments require prescribed methods and transaction analysis; an unexplained flat mark-up is unsustainable. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800466