https://www.taxtmi.com/caselaws?id=58880 Collaboration agreements executed before 1 April 1976 were analysed by separating licence/know-how consideration from technical assistance consideration. Receipts referable to supervision, erection, start-up and test-run services were treated as fees for technical services, not royalty, and fell within the proviso to section 9(1)(vii) because the agreements were pre-1976 and Government-approved. A separate lump sum component traceable to transfer of licence and know-how under the Nangal Expansion Project was characterised as royalty, but it was exempt under the proviso to section 9(1)(vi) for the same reason. The receipts were therefore not brought to tax. en-us Fri, 10 Feb 1989 00:00:00 +0530 Sun, 06 Feb 2011 02:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58880 Collaboration agreements executed before 1 April 1976 were analysed by separating licence/know-how consideration from technical assistance consideration. Receipts referable to supervision, erection, start-up and test-run services were treated as fees for technical services, not royalty, and fell within the proviso to section 9(1)(vii) because the agreements were pre-1976 and Government-approved. A separate lump sum component traceable to transfer of licence and know-how under the Nangal Expansion Project was characterised as royalty, but it was exempt under the proviso to section 9(1)(vi) for the same reason. The receipts were therefore not brought to tax. Case-Laws Income Tax Fri, 10 Feb 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58880