Court Rules on Royalty Payments u/s 9(1)(vi) of Income Tax Act: Partial Rights Transfers Are Royalties.

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....Royalty u/s 9(1)(vi) - acquisition of a partial right in the intangible property or know-how without the transferor fully alienating as the ownership rights - lump-sum payments are covered under the term royalty - it is not a case of outright sale - HC....