https://www.taxtmi.com/caselaws?id=60898 Lump sum consideration paid to a foreign collaborator for drawings, designs, specifications and technical documentation for manufacture in India is treated as royalty under the Income-tax Act because the payment is made for use of designs and for technical knowledge connected with those rights and property. The treaty analysis in the text likewise treats such royalty as taxable in India where the relevant convention preserves source taxation of royalty income, even if the foreign enterprise has no permanent establishment. The stated tax consequence is that tax is required to be deducted at source under section 195 on such payments. en-us Wed, 31 Aug 1994 00:00:00 +0530 Sun, 06 Feb 2011 03:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60898 Lump sum consideration paid to a foreign collaborator for drawings, designs, specifications and technical documentation for manufacture in India is treated as royalty under the Income-tax Act because the payment is made for use of designs and for technical knowledge connected with those rights and property. The treaty analysis in the text likewise treats such royalty as taxable in India where the relevant convention preserves source taxation of royalty income, even if the foreign enterprise has no permanent establishment. The stated tax consequence is that tax is required to be deducted at source under section 195 on such payments. Case-Laws Income Tax Wed, 31 Aug 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60898