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.... Where the gross total income of an assessee being an Indian company includes any income by, way of royalty, commission fees or any other payment (not being income chargeable under the head "Capital gains") received by it from any person carrying on a business in India in consideration for - (i) the provision of technical know-how which is likely to assist in the manufacture or process....

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....h income of an amount equal to forty per cent. thereof, in computing the total income of the assessee. (2) For the purposes of this section "provision of technical know-how means, - (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or similar property; (ii) the imparting of any informat....