Royalty earned by NR from another NR not taxable in India even if payer embeds the now-how into products sold in India

 ITAT DELHI BENCH ‘E’ Qualcomm Incorporated Versus ADIT, Circle 2(1) International Taxation IT APPEAL NOS. 3696 TO 3699 AND 3700 (DELHI) OF 2009 [ASSESSMENT YEARS 2000-01 TO 2004-05] JANUARY 31, 2013 ORDER J. Sudhakar Reddy, Accountant Member All these five appeals are filed by M/s.Qualcomm Incorporated and are directed against a common order passed by the CIT(A)-XXIX, New Delhi dt. 26-06-2009 for the A.Y. 2000-2001 to A.Y. 2004-2005. All these appeals arise from the assessments framed by the Assessing Officer (‘AO’) under section 143(3) read with sec...