Technical Know-How Sale u/s 9(1)(vi) IT Act Considered Royalty, Exempt from Tax Due to DTAA.

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....Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - The Seller had sold, assigned, conveyed and transferred to assessee its entire right, title, interest and ownership in the asset - not taxable in view of DTAA - AT....