https://www.taxtmi.com/caselaws?id=57564 The Tribunal dismissed the revenue's appeals and affirmed the CIT(A)'s decision that the payment received by the foreign company was not taxable in India as royalty under section 9(1)(vi) of the IT Act, 1961. The Tribunal determined that the services were performed outside India, making the amount a capital receipt rather than taxable income. The judgment highlights the significance of the situs of services and the nature of payments in cross-border transactions. en-us Wed, 31 Jan 2001 00:00:00 +0530 Fri, 10 Dec 2010 18:00:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57564 The Tribunal dismissed the revenue's appeals and affirmed the CIT(A)'s decision that the payment received by the foreign company was not taxable in India as royalty under section 9(1)(vi) of the IT Act, 1961. The Tribunal determined that the services were performed outside India, making the amount a capital receipt rather than taxable income. The judgment highlights the significance of the situs of services and the nature of payments in cross-border transactions. Case-Laws Income Tax Wed, 31 Jan 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57564