https://www.taxtmi.com/caselaws?id=57985 A renewed royalty arrangement with materially altered terms, including royalty structure, technology use, permitted markets and computation of net compensation, was treated as a fresh agreement rather than a continuation of the earlier contract, so the royalty income was taxable at 40% under section 115A(1)(b) instead of the higher rate applied by the tax . The same amount could not be subjected again to protective addition on cash basis where it had already been assessed on accrual basis in an earlier year and that earlier addition had been upheld. The departmental appeal was dismissed and both disputed additions were deleted in favour of the assessee. en-us Fri, 15 Sep 1989 00:00:00 +0530 Wed, 15 Dec 2010 17:05:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57985 A renewed royalty arrangement with materially altered terms, including royalty structure, technology use, permitted markets and computation of net compensation, was treated as a fresh agreement rather than a continuation of the earlier contract, so the royalty income was taxable at 40% under section 115A(1)(b) instead of the higher rate applied by the tax . The same amount could not be subjected again to protective addition on cash basis where it had already been assessed on accrual basis in an earlier year and that earlier addition had been upheld. The departmental appeal was dismissed and both disputed additions were deleted in favour of the assessee. Case-Laws Income Tax Fri, 15 Sep 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57985