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Service tax on royalty for technical know-how transfers overseas isn't IPR taxable unless registered in India u/s 65 (55a).
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....Levy of Service Tax - royalty paid to overseas entity - transferring of technical know-how cannot be equated to transfer of Intellectual Property Right and that as long as the said Intellectual Property Right is not registered or patented in India; the same would not qualify to be IPR taxable in India in terms of Section 65 (55a) of Finance Act, 1994. - AT....
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