Payment for transfer of comprehensive technical information / know-how which included all trade secrets, technical information, designs &drawings cannot be treated as royalty

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, ...