https://www.taxtmi.com/caselaws?id=58307 Lump sum consideration under a technology licence agreement was treated as royalty because it was paid for technical information, assistance and a licence to manufacture in India, together with use and transfer of know-how and related services. The treaty exclusion for industrial or commercial profits did not apply, and the receipt therefore remained taxable under the Income-tax Act. The consideration was held to fall within the statutory concept of royalty, including lump sum payments, and was chargeable in India without apportionment between operations inside and outside India. en-us Tue, 30 Oct 1990 00:00:00 +0530 Sun, 06 Feb 2011 03:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58307 Lump sum consideration under a technology licence agreement was treated as royalty because it was paid for technical information, assistance and a licence to manufacture in India, together with use and transfer of know-how and related services. The treaty exclusion for industrial or commercial profits did not apply, and the receipt therefore remained taxable under the Income-tax Act. The consideration was held to fall within the statutory concept of royalty, including lump sum payments, and was chargeable in India without apportionment between operations inside and outside India. Case-Laws Income Tax Tue, 30 Oct 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58307