Non-resident payment for technical info classified as royalty u/s 9(1)(vi) of Income Tax Act & India-Germany DTAA.

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....Royalty u/s 9(1(vi) - non resident assessee - Such payment for use of technical information and know how has to be considered as royalty both under the provisions of Income Tax Act and under the provisions of DTAA between India and Germany even if the payment is lump sump and not recurring - AT....