https://www.taxtmi.com/caselaws?id=60129 The appeals were allowed in part, with specific directions provided on each issue. The Tribunal held that the charging of interest under sections 215 and 217 of the Income-tax Act is appealable if the liability is disputed. It determined that the agreement dated 18-4-1980 was not a continuation of the earlier agreement dated 19-7-1974. The income under the 1980 agreement was classified as royalty and taxable. The definition of 'royalty' in the Act applied to the Double Taxation Avoidance Agreement (DTAA). The tax rate applicable to royalties was set at 40%. The Tribunal did not find sufficient evidence of grossing up by tax on tax basis. en-us Tue, 24 Feb 1987 00:00:00 +0530 Sun, 06 Feb 2011 03:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60129 The appeals were allowed in part, with specific directions provided on each issue. The Tribunal held that the charging of interest under sections 215 and 217 of the Income-tax Act is appealable if the liability is disputed. It determined that the agreement dated 18-4-1980 was not a continuation of the earlier agreement dated 19-7-1974. The income under the 1980 agreement was classified as royalty and taxable. The definition of 'royalty' in the Act applied to the Double Taxation Avoidance Agreement (DTAA). The tax rate applicable to royalties was set at 40%. The Tribunal did not find sufficient evidence of grossing up by tax on tax basis. Case-Laws Income Tax Tue, 24 Feb 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60129