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Payment for transfer of comprehensive technical information / know-how which included all trade secrets, technical information, designs &drawings cannot be treated as royalty
Case Law Details
- Case Name
- Commissioner of Income Tax Vs D.C.M. Limited (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
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Payment made for transfer of comprehensive technical information and know-how which included all trade secrets and technical information, designs and drawings, etc. cannot be treated as income from royalty under the India-UK tax treaty
Recently, the Delhi High Court in the case of CIT v. DCM Limited (ITR Nos. 87-89/1992) held that payments made for transfer of comprehensive technical information and know-how, which included all trade secrets and technical information, designs and drawings, etc. cannot be treated as income from royalty under the India-UK tax treaty (tax treaty). Accordingly, ...
