Merely because agreement named as license agreement is not enough to attract section 194-I

Advertisement RELEVANT PARAGRAPH  20. On examination of the license agreement and schedule attached with the same, we find that entire factory building along with plant & machinery have been given under the agreement by M/s. Ramco Ind. Ltd. to the assessee for taking over the production facilities. The agreement as a whole has to be considered. As per the agreement between licensee and licensor, there was a definite obligation of the assessee to make minimum licence fees of Rsy40 lakh and the rest was dependant on the production respectively for permitting the licensee to utilize all p...