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Assessment of income from royalties, fees for technical services. know-how fees.
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....by the foreign companies in the matter of assessment of income from royalties, fees for technical services. know-how fees, etc., were being admitted by the Income-tax Officers. From the sample taken, it has been observed that in some cases the expenses have been allowed as deduction more on an ad hoc basis rather than on a proper scrutiny of account books or statements of account. In most of the c....
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.... the fact whether any such current research results were actually being made available. 2. The Board consider this state of affairs to be highly unsatisfactory and desire that the claims for expenses should be scrutinised in depth in all foreign collaboration cases. For the purpose of arriving at the correct profits assessable in India, the Income-tax Officers should consider in appropriate cases....